Tax Disputes
Growing GAAR scrutiny is driving taxpayers to look beyond legal form and demonstrate the commercial rationale underpinning tax-efficient structures
Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Europe Tax Awards
The Court of Appeal ruling clarifies that treaty benefits are not abusive where transactions are commercially driven, providing greater certainty on “main purpose” anti-avoidance tests
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Sponsored by MachadoA single vote in 2020 looks set to end 25 years of confusion surrounding corporate income taxes and the offsetting of tax losses when companies terminate operations. Ana Lúcia Marra and Stephanie Makin of Machado Associados take a closer look at the much-debated 30% tax loss limit upon termination of companies and the pre-impact of the upcoming decision. -
Sponsored by MachadoUm único voto em 2020 pode dar uma nova perspectiva para 25 anos de controvérsias acerca da compensação de prejuízos fiscais na extinção das empresas. Ana Lúcia Marra e Stephanie Makin do Machado Associados comentam o tão debatido limite de 30% e o potencial impacto da decisão.
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Sponsored by EY ItalyDavide Bergami and Antonio Zegovin from Studio Legale Tributario EY explain why exploring an advanced pricing agreement (APA) is an attractive opportunity for multinational enterprises (MNEs) with operations in the country.
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