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News & Analysis

Legal Certainty and SP2DK in Indonesia: Between Clarification and Uncertainty

13 March 2026 by Provisio Consulting - Indonesia

In Indonesia’s tax administration framework, the Surat Permintaan Penjelasan atas Data dan/atau Keterangan (SP2DK) plays an increasingly prominent role in the Directorate General of Taxes’ compliance strategy. Designed as a pre-audit clarification mechanism, SP2DK reflects the tax authority’s shift toward data-driven supervision. However, from a legal certainty perspective, SP2DK presents structural ambiguities that merit closer examination.
News & Analysis

Transfer Pricing Tax Risk

13 March 2026 by TPC Group - Chile

Tax risk is that faced by companies that may be paying or accounting for an incorrect amount of tax (including income tax and indirect taxes), or that the tax positions taken by a company are incompatible with the tax risk expectations that administrators have approved or consider prudent.

News & Analysis

Elias Neocleous & Co LLC advises on Pelagic Credit Plc’s USD 75 million private placement and listing on Euronext Growth Oslo

11 March 2026 by Elias Neocleous & Co - Cyprus

Elias Neocleous & Co LLC acted as Cyprus legal counsel in connection with the successful completion of the USD 75 million private placement and admission to trading of the shares of Pelagic Credit Plc on Euronext Growth Oslo, one of the world’s leading capital markets for shipping and maritime-related companies. The company announced that the first day of trading of its shares on Euronext Growth Oslo took place on 9 March 2026.
News & Analysis

Elias Neocleous & Co LLC has advised on a landmark cross border financing of Allwyn exceeding EUR 2 billion including the issuance of senior secured notes

11 March 2026 by Elias Neocleous & Co - Cyprus

Elias Neocleous & Co LLC has advised in connection with the issuance of €550,000,000 aggregate principal amount of senior secured notes due 2031 by Allwyn.
News & Analysis

Judicial Intervention in Tax Dispute Resolution

11 March 2026 by Alliance Law Firm - Nigeria

The judiciary plays a crucial role in the administration of justice. Applicable tax laws in Nigeria clearly define the procedures for tax appeal and for challenging any decision of tax authorities.
News & Analysis

Safe Harbour Rules and the Nigerian Transfer Pricing Regulation – A Critical Examination

11 March 2026 by Alliance Law Firm - Nigeria

The transfer pricing regulations cover all transactions between ‘connected taxable persons’ that could impact the profit or loss position of any of the parties including transactions that entail the use of intangible assets, provision of goods or services, loans, lease or sale of assets; licensing, transfer, procurement etc.
News & Analysis

Franco Pozzi and Simona Zangrandi of Biscozzi Nobili & Partners examine secondary transfer-pricing adjustments under Italian tax practice

06 March 2026 by Studio Legale e Tributario Biscozzi Nobili & Partners - Italy

With judgment No. 4699 of November 26, 2025, the First Instance Tax Court of Milan ruled that, under the combined provisions of the Italy-Switzerland Double Taxation Treaty and OECD Commentary (paragraph 12.25), payments exceeding the arm's length value are not taxable as “royalty” in Italy.
News & Analysis

Doing Business in Venezuela 2026

02 March 2026 by Baker McKenzie - Venezuela

As Venezuela is transitioning into a new chapter of its history new investment opportunities may appear on the horizon. In this edition of Doing Business in Venezuela we present a comprehensive guide designed to help global investors, companies, and decision makers understand the legal and regulatory framework of the country.
News & Analysis

Indonesia Tax Flash: New Rule on Tax Resident and Update on EOI affecting CRS and Crypto

02 March 2026 by Metalaw Legal and Tax Consultant - Indonesia

The development of the digital economy and increased cross-jurisdictional mobility have prompted tax authorities in various countries to strengthen regulatory frameworks that ensure certainty in taxpayer status while enhancing global financial transparency. In Indonesia, these efforts are reflected in the issuance of Minister of Finance Regulation No. 108 of 2025 on the Technical Guidelines for Access to Financial Information for Tax Purposes, as well as Regulation of Directorate General of Tax No. PER- 23/PJ/2025 on the Determination of Domestic Tax Subjects and Foreign Tax Subjects.

News & Analysis

Venezuela: Hydrocarbon Fuels Benefit from Temporary Tax Relief

02 March 2026 by Baker McKenzie - Venezuela

On 9 January 2026, Decree No. 5,207 (“Decree”) was published in Official Gazette No. 43,292, under which the sales and imports of hydrocarbon fuels were exonerated from VAT, import tax, customs duties and "any other tax, rate or special contribution applicable".
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