Treat-ease? Not if GAARs and the PPT can help it
The implementation of general anti-avoidance rules (GAARs) has been an attempt to prevent the use of tax treaties to enable tax evasion, granting a country’s tax authority enough power to disregard a particular corporate structure or transaction, and deny a benefit granted by a double taxation treaty when tax avoidance could exist. Even so, the task of GAARs comes with challenges, as the interpretation of ‘when’ and ‘how’ GAARs should be applied can vary from one country to another. This session at the 2024 IBA Annual Conference in Mexico City discussed the status on the implementation of GAARs in Brazil, Mexico, Switzerland and the Netherlands.
Released on Nov 25, 2025
Structuring business investment into Mexico
This panel at the 2024 IBA Annual Conference in Mexico City addressed the main recent developments in the tax structuring of foreign investments into Mexico. Considering that such foreign investments are predominantly made by United States investors (41.4 per cent of investment over the period 2006–2024), and by Spanish investors (10 per cent of investment over the same period), the panel focused first on the main general tax implications arising in Mexico for foreign investors.
Released on Nov 25, 2025
Mandatory reporting and the preservation of client rights to privacy, access and privilege
Mandatory reporting obligations adopted by different jurisdictions have created tensions between fundamental principles such as solicitor-client privilege, confidentiality and transparency. As countries implement stricter reporting regimes, different parties face challenges balancing compliance with these principles. This panel at the 2024 IBA Annual Conference in Mexico City discussed the approaches and current developments in different countries on these subjects.
Released on Nov 25, 2025
Tax-AI-tion and the digital divide – how does artificial intelligence impact on tax practice?
This panel at the 2024 IBA Annual Conference in Mexico City provided an in-depth exploration of the challenges and opportunities that AI presents to taxation and transfer pricing. Experts from various countries, including Argentina, Brazil, Mexico, South Korea and Spain, addressed how AI impacts value chains, the evolving role of AI in tax administration, and the regulatory frameworks needed to ensure fair practices.
Released on Nov 25, 2025
Employers of record: a global review of immigration, employment and tax issues
This panel discussion at the 2024 IBA Annual Conference in Mexico City examined the complexities associated with the employer of record (EOR) model in global employment contexts. The panel featured legal experts from different regions, who shared their insights on the challenges, limitations and operational strategies associated with EORs.
Released on Nov 25, 2025
Business without borders: managing the impacts of corporate and C-suite mobility
This panel at the 2024 IBA Annual Conference in Mexico City addressed the primary fiscal challenges associated with cross-border corporate and executive mobility, including issues related to permanent establishments, place of effective management and their consequences – such as exit taxes – in Brazil, Italy, Mexico, Portugal, Switzerland, and the United States.
Released on Nov 25, 2025
Tax considerations in the digital economy
This panel at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024, analysed how different countries implement new tax regimes in the digital economy era, particularly by addressing the current legislative landscape and the challenges experienced and efforts made by each jurisdiction.
Released on Nov 24, 2025
Startups and new businesses: tax planning for long term success
This panel at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024 addressed on a country-by country basis the various tax considerations for startup businesses in Latin America looking to expand both domestically and abroad. Additionally, the panel also discussed the tax considerations for US businesses looking to expand into Latin America.
Released on Nov 24, 2025
Impact of GAARs and mandatory disclosure on client advice
Domestic law is often used to combat abuse and tax planning. Some countries apply anti-avoidance rules independently if there is no anti-avoidance clause included in the relevant tax treaty to avoid double taxation. Other tax treaties expressly authorise it, among others due to the entry into force of the multilateral instrument. Clients are increasingly facing the application of general anti-avoidance rules (GAARs) in connection with anti-avoidance rules included in tax treaties, together with increased mandatory disclosure rules (MDRs). This panel at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024, discussed GAARs and MDRs in several jurisdictions, and the impact thereof on client advice.
Released on Nov 24, 2025
HNW clients: transparency in the United States and Latin America
This panel – at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024 – focused on the evolving landscape of tax transparency and compliance for high net worth (HNW) individuals and multinational businesses in the US and Latin America.
Released on Nov 24, 2025
Exiting and moving out: entity shut down – where, when and why?
This panel at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024, focused on why multinationals consider migrating and the most common recipient jurisdictions. The panel navigated the country specific tax and non-tax reasons considered by decisionmakers when facing these migrations.
Released on Nov 24, 2025
Financing and investing in energy, critical minerals and renewables in the Americas
This session – at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024 – began with a brief overview of relevant facts including that energy and extractives covers a broad range of activities in different industries and different stages of production. The relevance of any particular industry or activity varies from country to country throughout the Americas, as does the level of private participation, which also varies from industry to industry and even project to project
Released on Nov 24, 2025
Defending multiple fronts – the prevalence, perils, and best practices of parallel civil and criminal tax enforcement proceedings
The chair commenced this session – at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024 – by outlining the key subjects that the speakers would cover regarding the implementation of civil and criminal tax regulations across different countries. Additionally, he provided a concise introduction to tax loopholes and the investigative tools employed by authorities in criminal proceedings. He also underscored the significance of the Pandora papers, and the widespread impact this phenomenon has had on various countries.
Released on Nov 24, 2025
Current legislative trends
This report summarises a panel discussion – at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024 – on current legislative trends in taxation. As introduced by Ana Cláudia Utumi, the panel focused on tax reforms; the implementation of the OECD’s Pillar Two; and tax certainty, tax audits and tax litigation.
Released on Nov 24, 2025
The current state of M&A in Latin America and beyond
This panel at the 16th IBA/ABA US and Latin America Tax Practice Trends Conference in Miami, in June 2024, focused on highlighting the specificities applicable in different jurisdictions regarding M&A operations, as well as the relevant trends in each and the region-specific challenges.
Released on Nov 24, 2025
Who really has beneficial ownership? Considerations for cross-border wealth management structures
This Wealth Management Workshop panel at the 25th Annual IBA/ABA US and Europe Tax Practice Trends conference in Amsterdam, in April 2025, convened to explore the evolving landscape of beneficial ownership, particularly in the context of wealth management, tax transparency, cross-border structures and international compliance. Gathering legal experts from the United States and across Europe, the panel offered comparative insights into domestic and cross-border regulatory frameworks.
Released on Nov 4, 2025
Structures and strategies for private credit funds
Gathering legal experts from the United States and across Europe, this panel at the 25th Annual IBA/ABA US and Europe Tax Practice Trends conference in Amsterdam convened to discuss structuring considerations, strategies and other emerging issues relevant for private credit funds.
Released on Nov 4, 2025
Cross-border VAT: challenges, opportunities and the future of tax compliance
This panel at the New Era of Taxation conference in Milan, in September 2025, discussed the complexities of VAT on cross-border transactions with a specific focus on the supply chain of goods supplied by a non-European Union taxable person into the EU and subsequent intra-community supplies. As the panel was composed of experts from Germany, Italy, Austria and Switzerland, each of the speakers shared their insight on the VAT treatment and challenges encountered in their respective jurisdictions.
Released on Nov 4, 2025
Modernising payments and cross-border tax refunds: the implications of US Executive Order 14247
Executive Order (EO) 14247, Modernising Payments To and From America's Bank Account, mandates an end to paper cheques for all United States federal payments, including tax refunds, by 30 September 2025. This article analyses the EO’s impact on expatriate assignees, inbound non-resident taxpayers, multinational employers and non-US individuals or entities with US tax obligations.
Released on Jul 23, 2025
VAT on digital services in Sri Lanka: taxing the cross-border supply of services provided by electronic platforms
This article examines the imposition of VAT on digital services in Sri Lanka, specifically focusing on the supply of services by non-residents via electronic platforms to Sri Lankan consumers. It explores the current legislative framework, implementation challenges and the broader implications on the cross-border supply of digital services.
Released on Jul 18, 2025
It’s a matter of trust: foreign grantor trusts and other trust developments
This panel, at the 25th Annual US and Europe Tax Practice Trends Conference held in Amsterdam on 9 April 2025, discussed foreign grantor trusts in a cross-border context, focusing specifically on cases where US citizen settlors or beneficiaries of a US grantor trust relocate to Europe.
Released on Jul 17, 2025
Reversions: coming back to US-based multinationals
This panel at the 25th Annual US and Europe Tax Practice Trends Conference held in Amsterdam on 10 April 2025 discussed various topics related to multinational companies relocating back to the US and the different push and pull factors.
Released on Jul 17, 2025
Cross-border tax crimes [2025]
This session at the 25th annual IBA/ABA US and Europe Tax Practice Trends Conference in Amsterdam brought together legal experts from various jurisdictions to delve into the complexities of global tax evasion and fraud.
Released on Jul 17, 2025
M&A hot topics (2025)
This conference session at the 25th Annual US and Europe Tax Practice Trends Conference held in Amsterdam in April 2025 discussed a range of hot topics in regard to M&A. The co-chairs and the panellists elaborated on the relevant considerations, tax and non-tax related, relating to the choice of the top company jurisdiction in a merger of equals involving a US group and a non-US group. They also discussed recent trends relating to take-private deals in their respective jurisdictions.
Released on Jul 17, 2025
Luxembourg’s competitive edge: tax reforms to attract talent
Luxembourg continues to consolidate its position as a leading jurisdiction for wealth management and investment structuring, being notably the first fund centre in Europe and second only to the United States globally. This situation is underpinned by a series of legislative reforms, fiscal incentives and regulatory enhancements in the country. In this context, the Minister of Finance, Gilles Roth, has recently underscored the strategic imperative of leveraging current geopolitical and technological developments to reinforce Luxembourg’s global competitiveness.
Released on Jul 16, 2025
Alternative mechanisms for tax dispute resolution in Mexico: a strategic approach amid judicial uncertainty
This article analyses the recent evolution and strategic advantages of alternative mechanisms for tax dispute resolution in Mexico, otherwise known as Mecanismos Alternativos de Solución de Controversias (MASC), mutual agreement procedures (MAPs) and investment treaty arbitration, especially in the context of institutional uncertainty and weakened judicial independence.
Released on Jul 16, 2025
Reviving the stamp tax in Colombia: a step backwards?
This article examines the reinstatement of Colombia’s stamp tax in 2025, questioning whether reviving a historically inefficient and outdated tax is a sound response to a public emergency. It explores the tax’s origins, current scope and broader implications of the change in regard to fiscal policy and legal certainty.
Released on Jul 14, 2025
Cross-border credit assignments and withholding tax in Chile
This article analyses the Chilean tax implications of assigning monetary credits in cross-border transactions. It focuses on the treatment of accrued interest, the effects of the assignment itself and the tax consequences for Chilean assignees, based on the recent interpretation issued by the Chilean Internal Revenue Service (Servicio de Impuestos Internos or SII) in Ruling No 801 of 2024.
Released on Jul 14, 2025
Spain’s changing tax landscape for real estate: key developments and proposals
This article analyses recent and proposed changes to the Spanish real estate tax framework, with a particular focus on the measures implemented in Catalonia and a controversial nationwide draft bill. The key issues discussed include increased transfer taxes, value-added tax (VAT) adjustments and the implications for non-EU investors.
Released on Jul 14, 2025
ABC: AI, Big Data and crypto
This session at the 14th Annual IBA Finance & Capital Markets Tax Conference discussed the future of artificial intelligence and its role in the legal profession, the increased use of Big Data by tax administrations and the taxation of cryptocurrency.
Released on Jul 11, 2025