Wopke Hoekstra takes tax hotseat in new EU Commission; in other news, Latham boosts energy tax expertise and Fieldfisher expands Spanish tax practice
Australian Greens senator Barbara Pocock told ITR that parliament may need to use its powers to compel PwC to hand over elusive documents related to its tax leaks scandal
The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours
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 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
ITR is delighted to reveal all the shortlisted nominees for the 2024 Asia-Pacific Tax Awards
As the firm declined to speak with ITR over its progress, senator Deborah O’Neill branded PwC Australia’s recent parliamentary responses as ‘unsatisfactory’
A Swedish company’s CEO working part-time in Denmark led to a noteworthy PE decision; in other news, Latham & Watkins grew its London tax team
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
Ursula von der Leyen is under pressure to ensure her new team makes competitiveness a top priority. How tax policy is designed and implemented is crucial, writes Ralph Cunningham
The lack of provision for bilateral advance pricing agreements is a notable omission from proposed reforms of Brazil’s transfer pricing rules
Speaking exclusively at ITR’s Transfer Pricing Forum in Europe, the Commission’s Marc Clercx also addressed industry concerns over the arm’s-length principle
White & Case’s tax controversy head discusses how to stop a dispute before it starts and shares insights from a significant TP case with the IRS
The court overturned a common and well-established position of the Italian tax authorities in a highly significant ruling, experts have told ITR
US calls for talks with Canada over digital service tax, Argentina cuts withholding taxes, and more
European Commission and India talk CBAM, Infosys says no to VAT non-payment allegation, and more
The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year
The party should aim to reduce corporation tax from 25% to 15%, one partner told ITR
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
Features and Special Focus
Transfer Pricing Guide
April 25, 2024
Sponsored
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici analyse the options excercised and choices made by Italy when transposing the provisions of the Public Country-by-Country Reporting Directive
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Sponsored by VRMA AdvogadosThe Supreme Federal Court has returned to a case that could have a huge economic impact on the federal government, report Paulo Victor Vieira da Rocha and Camila Montenegro Cruz of VRMA Advogados
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Sponsored by MDDPMagdalena Marciniak and Agnieszka Krzyżaniak of MDDP consider whether two recent rulings indicate that Polish taxpayers can look forward to a more positive landscape for transfer pricing adjustments
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Sponsored by DLA Piper AustraliaJock McCormack of DLA Piper Australia summarises Australia’s latest proposed double tax agreement as the country’s treaty reforms gather pace, and potential changes to the non-resident capital gains tax withholding rate and threshold
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Sponsored by DeloitteDeloitte’s Tax Transformation Trends survey has highlighted key considerations for organisations shaping their talent strategies. Mary Fabean, Gina Salama, and Michelle Tariq of Deloitte suggest five ways to adapt to a rapidly changing tax environment
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Sponsored by GNV ConsultingThis month’s summary, by Ahdianto Ah and Reza Farhan of GNV Consulting, also explains a regulation providing for an import duty exemption on certain seeds and seedlings, and new supervisory powers for customs officials
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente report on a ruling by the Italian Tax Agency and explain an update to the deadline for the submission of income tax returns
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services casts a critical eye over the ‘odd and complex’ implementation of a new system that is designed to simplify Spain’s corrective VAT returns process
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados explains the contrasting viewpoints and legislative developments regarding the taxation of goods moved between branches of the same company
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Sponsored by insightsoftwareJoin ITR and insightsoftware at 2pm BST (3pm CEST) on September 24 to hear senior tax experts from KPMG Canada explain the evolving pillar two requirements and the transitional safe harbours – and consider what comes next
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Sponsored by Lakshmikumaran & SridharanS Vasudevan and Harshit Khurana of Lakshmikumaran & Sridharan consider the winners and losers as India removes the 2% equalisation levy on overseas e-commerce operators to facilitate its implementation of the OECD’s pillar one solution
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Sponsored by DeloitteJobst Wilmanns and Anodri Suchdeve of Deloitte Germany introduce this year’s ITR guide presenting transfer pricing insights across several industries, with analysis from Deloitte’s transfer pricing industry experts and factoring in global economic changes
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Sponsored by DeloitteRalf Heussner of Deloitte Japan and Aaron Lee of Deloitte Singapore examine the latest transfer pricing trends impacting the banking sector in view of the implementation of the new Basel accord from 2025
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Sponsored by DeloitteGeoff Gill and Michael Manser of Deloitte Australia provide a guide to the upcoming public country-by-country reporting measures and how multinationals in the financial services sector should prepare for the first year of reporting
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Sponsored by DeloitteWith ever-increasing challenges in the wholesale and retail industry, senior tax practitioners at Deloitte Germany consider the impact of amount B on the profit allocation of multinationals operating in the sector
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Sponsored by DeloitteIshan Maini of Deloitte UK and Jay Das of Deloitte US say the need for technology, media, and telecommunications companies to analyse the risks associated with intercompany transactions has never been greater
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Sponsored by DeloitteClaudia Lauten, Janis Sussick, and Karen Smolka of Deloitte discuss how amount B could impact the tax and transfer pricing approaches of global multinational enterprises in the industrial products and construction sector
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Sponsored by DeloitteRichard Schmidtke, Heike Schenkelberg, and David Sauer of Deloitte Germany analyse the impact of specific characteristics of the life sciences and healthcare industry on the applicability of amount B
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Sponsored by CuatrecasasMaria Inês Cotrim and Sofia Alves Pires of Cuatrecasas explain Portugal’s property transfer tax applied to share transfers and the tax authority’s interpretation of the non-allocation of real estate assets to economic activities requirement
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Sponsored by DLA Piper NetherlandsJian-Cheng Ku and Roland Kleimann of DLA Piper Netherlands analyse how corporate reorganisations involving Dutch entities are impacted by the ‘excessive severance payment levy’
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Sponsored by DeloitteJobst Wilmanns and Anodri Suchdeve of Deloitte preview a guide to the latest transfer pricing trends, produced in collaboration between ITR and global transfer pricing industry experts from Deloitte
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Daniel Canola of Gatti Pavesi Bianchi Ludovici highlight some noteworthy aspects of the envisaged introduction of a cross-border relief for tax losses in Italy, fostered by the CJEU’s case law
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Sponsored by Dhruva AdvisorsAditya Hans, Ashish Jain, and Nilesh Chandak of Dhruva Advisors provide an update on India’s implementation of the OECD’s tax reforms after the Union Budget 2024–25 and consider the GloBE rules’ potential impact
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Sponsored by HLB ThailandAmit Bhalla and Andrew Jackomos of HLB Thailand explain the Thai Revenue Code’s guidance in determining the nature of the relationship between two entities and whether transfer pricing disclosure forms are required
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Sponsored by GNV ConsultingCharles Setia Oetomo and Erviyanti Adam of GNV Consulting report that 37 types of administrative tax services can now be accessed using various ID numbers, and Indonesia has also updated several tax treaties
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Crowe Valente/Valente Associati GEB Partners consider the ramifications of a ruling concerning the inclusion of loss-making companies in a transfer pricing benchmarking analysis as comparable entities
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Sponsored by DLA Piper AustraliaAdam Smith of DLA Piper Australia reviews a raft of proposed Australian tax law changes, including a widened scope of capital gains tax for foreign residents
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services reports on a pronouncement by an EU member state on the impact that transfer pricing adjustments have on the VAT applied to transactions
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Sponsored by Wolters KluwerJoin ITR and Wolters Kluwer on September 3 2024 for insights from the latest Wolters Kluwer BEPS Pillar Two Readiness Index Report and advice on the practical steps needed to prepare for pillar two compliance
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Sponsored by MDDPPiotr Paśko and Tomasz Janik of MDDP say that while application of the tax exemption has historically been challenging, foreign investment vehicles stand to benefit as a more favourable environment appears to be emerging
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Michele Bissoli of Gatti Pavesi Bianchi Ludovici examine the new ‘reshoring regime’, a set of tax incentives and benefits aimed at encouraging companies to relocate their operations back to Italy
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Sponsored by Ritch MuellerSantiago Llano Zapatero and Fernando Caballero Gout of Ritch Mueller examine the state-imposed taxes applicable to specific transactions in certain states in Mexico
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Sponsored by Dhruva AdvisorsJoin Dhruva Advisors, Taxsutra, and ITR from 12.30pm–2pm BST (5pm–6.30pm India Standard Time) on July 23 to hear expert analysis of the implications of the tax proposals in India’s 2024–25 budget
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss treaty articles 12 and 13 within the context of national case law concerning the taxation of fees paid for imported technical services
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Sponsored by KPMG SwedenMaria Andersson Berg of KPMG Sweden explains the main proposed amendments and says joint calculation of the deduction base and net interest income will create a more favourable system for most groups
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Sponsored by MDDPApplication of the GloBE rules will present a challenge for the Polish legislature as it seeks to maintain the country’s appeal as an investment location, say Monika Marta Dziedzic and Łukasz Kumkowski of MDDP
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Sponsored by Vieira de Almeida & AssociadosVítor Loureiro e Silva and Duarte Canau of Vieira de Almeida & Associados discuss the key aspects of the Portuguese exemption waiver regime and whether it is in accordance with EU law and principles
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Sponsored by GNV ConsultingFabian Abi Cakra and Aditya Nugroho of GNV Consulting report that Indonesia’s reservations now cover 13 countries, while new regulations have addressed export duty rates for metal mineral products and tax administration systems
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain the benefits and recently updated provisions of the cooperative compliance regime