Corporate tax
October 2026 | SPECIAL REPORT: CORPORATE TAX
Financier Worldwide Magazine
October 2026 Issue
ATAD 3 and re-engineering economic substance
Over the next three to five years, we can expect substance requirements to become more integrated with broader tax transparency and compliance frameworks rather than through a standalone ‘Unshell’ regime. FW discusses ATAD 3 and re-engineering economic substance with Romain Tiffon at ATOZ Tax Advisers.
Do private equity funds need any economic substance?
It is sometimes argued that fund structures and their holding companies create an artificial tax benefit for investors by reducing or eliminating withholding tax on distributions or payments by the operating portfolio company, compared to a direct investment.
OECD transfer pricing chapter seven rewrite: modernisation or more disputes?
The success of the revised chapter seven will ultimately be measured by its ability to increase legal certainty, reduce disputes and promote consistent outcomes across jurisdictions.
Spain intensifies its scrutiny of transfer pricing
J&A Garrigues Transfer pricing in Spain is being tested with increasing rigour, both administratively and judicially, and multinational groups that revisit their intragroup arrangements now, rather than waiting for an inspection, are in a far stronger position to manage the likely risk they could face in the future.
Canada’s EIFEL rules in practice
Davies Ward Phillips & Vineberg LLP Traditional cross-border financing structures may no longer be viable under EIFEL and it may be necessary to alter the capital structure of Canadian subsidiaries or make various tax elections to increase interest deduction capacity.
Tax dispute activity across Africa has intensified, driven by fiscal pressures and revenue authorities’ efforts to maximise domestic collections. FW discusses tax disputes in Africa with Dominic Stuttaford at Norton Rose Fulbright, Elle-Sarah Rossato at PwC South Africa and Jashwin Baijoo at Tax Consulting South Africa (Pty) Ltd.
CONTRIBUTORS
ATOZ Tax Advisers
Davies Ward Phillips & Vineberg LLP
J&A Garrigues
Norton Rose Fulbright
PwC South Africa
Tax Consulting South Africa (Pty) Ltd.