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Showing 8341 - 8350 of 8916 for "Tax controversy" with applied filters

News & Analysis

AKD expands tax practice in Belgium with the appointment of Frédéricq Jacquet as partner

06 July 2023 by AKD - Belgium

AKD has taken on Frédéricq Jacquet for its tax practice as of 3 July 2023.

News & Analysis

Baker McKenzie announces the promotion of Olivier Dal Farra as a tax partner

05 July 2023 by Baker McKenzie - Luxembourg

Baker McKenzie Luxembourg is thrilled to announce the promotion of Olivier Dal Farra to Partner in our tax practice group, effecting from 1 July 2023.

News & Analysis

Baker McKenzie Luxembourg announces new Counsel’s promotion

05 July 2023 by Baker McKenzie - Luxembourg

It is with immense pleasure that Baker McKenzie Luxembourg announces the promotion of two counsel in the Tax and Transfer Pricing Practice Group, effecting from 1 July 2023.

News & Analysis

Tax Changes for 2023 and Their Effects on Transfer Pricing Rules

28 June 2023 by TPC Group - Peru

The tax authorities' innovations to be implemented must be known, concerning Transfer Pricing in particular.

News & Analysis

Luxembourg: Clarifications on reverse hybrid entities

28 June 2023 by Baker McKenzie - Luxembourg: Diogo Duarte De Oliveira, Amar Hamouche and Antonio Weffer

On 9 June 2023, the Luxembourg tax authorities issued a long awaited circular1 ("Circular") on reverse hybrid provisions as set forth under Article 168quater of the Luxembourg Income Tax Law (LITL). The purpose of the Circular is to provide guidance on determining the net income and tax due by taxpayers falling under the scope of Article 168quater LITL, i.e., being reverse hybrids.

News & Analysis

Old vs new: does the wording of the GAAR really matter?

28 June 2023 by PLMJ - Portugal : Dinis Tracana and Rita Medalho

The Portuguese Arbitration Court (‘CAAD’) has recently ruled in three similar cases dealing with the application of the General Anti-Avoidance Rule (‘GAAR’).

News & Analysis

Luxembourg: Transfer pricing documentation requirements and new advance pricing procedures - highlights of the main changes

15 June 2023 by Baker McKenzie - Luxembourg: Diogo Duarte de Oliveira, Amar Hamouche and Antonio Weffer

On 28 March 2023, the government presented Bill of Law 8186 ("Bill"), which provides a set of amendments to the General Tax Law (Abgabenordnung, AO) dated 22 May 1931. Amongst others, the bill introduces new bilateral and multilateral advance pricing agreement procedures, together with the possibility to issue, withdraw or amend a tax assessment further to a mutual agreement procedure (MAP) or an arbitration decision.

News & Analysis

Increase in Transfer Pricing Audits in Latin America

15 June 2023 by TPC Group - Peru

At the 7th International Tax Law Congress, organized by the Administrative Tax Court on Transfer Pricing, the perspectives thereon in Latin America were discussed, which highlighted the increase in the number of Transfer Pricing audits.

News & Analysis

Evolution of TP case law in Luxembourg — from zero to 100 in record time

08 June 2023 by Baker McKenzie - Luxembourg: Antonio Weffer, Elodie Schmidt

In the past few years, the Luxembourg tax authorities (LTA) have shown a growing interest in the examination of transfer pricing (TP) aspects of transactions carried out by multinational groups.

News & Analysis

Analysis Regarding the Transfer Pricing Harmonization Trend

05 June 2023 by TPC Group - Peru

Through an article published in the International Taxation blog Legal Today, Juliette Torres Ramos, a specialized lawyer in International Tax and Transfer Pricing, expressed the possibility of international harmonization and consensus on Transfer Pricing with a view to 2022.

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