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Italy introduces new documentation requirements for anti-hybrid mismatch rules

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

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

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

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

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

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