The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says
The UK regulator is investigating EY’s auditing of the national postal service as it relates to the high-profile Horizon scandal, which saw hundreds wrongfully convicted
The directive will extend cooperation and information exchange around pillar two, according to the Council of the EU
What Corporates Want: Southeast Asian advisers bottom on budgets
Cultural nuances could account for Southeast Asian tax advisers’ perceived poor cost management, a local partner told ITR
Talent Tracker Annual Review: Three firms share US top spot
Holland & Knight, Nelson Mullins and McCarter & English made the joint-most tax partner hires in the US last year, according to ITR's Talent Tracker
Featured Global Tax 50 profiles
ITR presents the 50 individuals who exerted the most influence on tax during 2024 – for better or worse – with world leaders, in-house award winners, activists and others making the cut
Awards
Awards
ITR invites tax firms, in-house teams, and tax professionals to make nominations for the 2025 ITR Tax Awards in the Americas, EMEA, and Asia-Pacific
Awards
The firm also won regional awards for Pro Bono Firm of the Year and Tax Law Firm of the Year
Awards
The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2024 Americas Tax Awards
Direct Tax
Taxpayers with Brazilian operations should revisit their withholding positions in light of updated US guidance, writes Rafael Benevides, senior tax counsel at Meta
While nearly all large firms said they were already using GenAI, only 63% of small firms reported the same
The OECD’s minimum tax rules will require enhanced due diligence from buyers, says Osborne Clarke partner Esther Villa
A global tax framework may not materialise anytime soon, but a common set of principles is becoming increasingly necessary, Rudolf Winkenius also tells ITR
Transfer Pricing
The MEGlobal Canada decision highlights taxpayers’ frustrations over split jurisdiction for TP assessments as well as a need for legislative reform, one expert tells ITR
The ruling is ‘well-structured’ in its references to the OECD TP guidelines, one expert says, while another argues it overlooks key technical issues
India also brokered its first-ever multilateral APA last year, the Central Board of Taxes announced
Looking at transfer pricing simplification is “obviously helpful”, but it should be done in line with current standards, a senior government figure reportedly said
Indirect Tax
The new tariffs could force companies to reroute logistics, renegotiate crucial deals or even uproot their production facilities, one tax expert tells ITR
The EU is preparing countermeasures to protect its interests, Ursula von der Leyen said; in other news, the NRA is suing the state of Colorado over a 6.5% tax on the sale of firearms
Kingsley Napley’s claimants are arguing that taxing the provision of education breaches the European Convention on Human Rights
Wopke Hoekstra implored US officials to ‘truly look into the facts’; in other news, the EU Council has reached a political agreement on DAC9
Jurisdictions
Features and Special Focus
Features and Special Focus
Transfer Pricing Guide
April 25 2024
Sponsored
Sponsored
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Sponsored by Skeppsbron SkattMikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters -
Sponsored by YulchonWith South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy
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Sponsored by Tax PartnerMonika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance
