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
A global tax framework may not materialise anytime soon, but a common set of principles is becoming increasingly necessary, Rudolf Winkenius also tells ITR
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
This week in tax: PwC reportedly reaches multimillion-dollar settlement with ex-partner over payouts
The deal comes after PwC had accused Paul McNab of using confidential information; in other news, McDermott hired a new London tax head from a US rival
The UK Government’s plans to close the tax gap via increased HM Revenue and Customs investment have failed to impress local tax advisers
Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements
KPMG Law US revolves around contract managed services and the US is the largest market for that, Stuart Bedford tells ITR in an exclusive interview
Transfer Pricing
Looking at transfer pricing simplification is “obviously helpful”, but it should be done in line with current standards, a senior government figure reportedly said
Updated rules represent a significant shift in the Luxembourg TP landscape and emphasise the need for robust arm’s-length calculations, says Vanessa Ramos Ferrin of TransFair Pricing Solutions
Other reasons included the complexity of reporting, resource constraints and interactions with tax administrations
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR
Indirect Tax
Wopke Hoekstra implored US officials to ‘truly look into the facts’; in other news, the EU Council has reached a political agreement on DAC9
The US president’s flippant approach to international trade will cause chaos for corporations, but there are opportunities for intrepid tax advisers
Singapore extends GST remission in 2025 budget; UK closes in on e-invoicing; two new partners at RSM Belgium ;and more
The plan, outlined by EU tax commissioner Wopke Hoekstra, would reportedly free 180,000 of the 200,000 in-scope businesses from additional compliance
Jurisdictions
Features and Special Focus
Features and Special Focus
Transfer Pricing Guide
April 25 2024
Sponsored
Sponsored
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Sponsored by RSM IndonesiaBusinesses must embrace a new tax paradigm with Indonesia’s adoption of pillar two. Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explore the impact on compliance, transfer pricing, and tax incentives -
Sponsored by EY RomaniaClaudia Sofianu and Dan Răuț of EY Romania summarise the new directive on platform work and call for Romania to continue its drive towards increased tax compliance and reduced tax evasion in this area
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Sponsored by DeloitteSenior Deloitte tax practitioners examine how international remote work is reshaping tax policy and explore the challenges businesses and governments face in navigating corporate, individual, and social security taxation
