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The memorandum raises concerns and taxpayer challenges should be expected, four experts tell ITR
The committee is deciding whether to add the appendix to existing guidance for tax administrations when scrutinising MNE activities
Companies that master the DEMPE analysis of their intangibles stand to benefit from a greater economic return, writes Mohamed Haj Taieb, partner at CMS France

Introducing ITR+'s Talent Tracker

ITR+ has launched the Talent Tracker, an interactive database that collates reported partner moves across the legal tax market

What Corporates Want: how law firms can win business

Based on surveys covering more than 25,000 in-house lawyers, the series provides insights into what law firms must score highly on when pitching to in-house counsel
The firm also won regional awards for Pro Bono Firm of the Year and Tax Law Firm of the Year
The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours
ITR is delighted to reveal all the shortlisted nominees for the 2024 Americas Tax Awards
ITR is delighted to reveal all the shortlisted nominees for the 2024 Europe Middle East & Africa Tax Awards
Roscoe, CEO of UK R&D tax relief consultancy RCK Partners, tells ITR about fatherly inspirations, his love of tennis, and what makes tax cool
Meanwhile, African revenue authorities expect their next taxable income to come from TP and from a larger share of the global tax bill, one expert tells ITR
The Labour Party’s hands-off approach to tax during the UK election campaign could be construed as political savviness, but as the October budget looms, reality will settle in
There were mixed emotions from campaigners against the controversial rules after last-minute negotiations on redrafting the provisions took place
Amount B was top of the agenda at ITR’s US Transfer Pricing Forum 2024, while there were also heated discussions on the US’s potential adoption of pillar two
HMRC is 'showing us what good looks like', one expert has claimed
Dutch taxpayers will be able to deduct more of their interest payments from their tax bills from 2025 – it could have an impact on the arm’s-length pricing of financial transactions
Vittoria Segre, partner at CMS Italy, reviews a range of TP topics discussed at the event, including financial transaction audits and permanent establishment issues
The UK tax agency dished out £153 million in VAT penalties last year; in other news, Bird & Bird and Pérez-Llorca have made strategic tax hires
Csaba Farkas of TMF Group outlines the practical steps businesses need to follow to take full advantage of the e-invoicing revolution
UK government looks to introduce e-invoicing, Grant Thornton hires from the ‘big four’ in Ireland, and more
Rather than outright replace human intelligence, AI solutions can serve as the ‘infinite intern’ tax advisers need to automate onerous tasks, argues Russell Gammon of Tax Systems
Werfel is commissioner of the US Internal Revenue Service
Jordan is commissioner of the Australian Taxation Office
Agergaard is the director of Skatteforvaltningen, the Danish tax authority
Scalia is head of tax at Nestlé Health Science and chair of the Tax Executives Institute’s Student Case Competition
Jurisdictions
Features and Special Focus

Deloitte TP Controversy Guide

Latin America Guide

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Transfer Pricing Guide

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