Italy introduces new documentation requirements for anti-hybrid mismatch rules
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain the conditions that transfer pricing documentation must satisfy to allow taxpayers to benefit from Italy’s penalty protection regime concerning hybrid mismatches
ITR’s European litigation report finds firms raring for TP disputes
Firms are starkly divided on the benefits of specialist tax litigation teams over generalist practices, ITR’s analysis also finds
Amount B reservations holding up pillar one agreement, OECD reveals
Just one member objected to the multilateral convention on amount A, citing concerns over amount B
Tax disputes a chief concern for 25% of in-house lawyers
Baker McKenzie’s survey of 600 corporate counsel also found that global employee mobility issues were a key driver of tax controversy
Pillar two to target 49% of shifted corporate profits: Slovakia report
Multinationals will continue to shift profits out of Slovakia to EU member states despite pillar two’s implementation, according to the report
Sweden: The right to judicial review of claims for corresponding adjustments
Thomas Andersson and Tobias Almqvist of KPMG Sweden discuss a Supreme Administrative Court ruling affirming the right to judicial review of corresponding adjustments under tax treaties, ensuring legal remedies for double taxation disputes