The OECD is confident it will smooth relations with non-pillar two countries like the US but warned it’s a politically sensitive issue, ITR’s inaugural Pillar Two Forum heard
Minkovich, a US-based tax partner at Baker McKenzie, tells ITR about cramming 600-page regulations, Roman archaeological digs, and what makes tax cool
Wopke Hoekstra takes tax hotseat in new EU Commission; in other news, Latham boosts energy tax expertise and Fieldfisher expands Spanish tax practice
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
Jim Chalmers’ opposite number also criticised the embattled firm, but argued that the government’s response to the tax leaks scandal had gone too far
The firm’s new Asia-Pacific head James Badenach tells ITR that A&M Tax can provide an alternative in the region to a “constrained” ‘big four’
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
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
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
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
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 -
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
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Sponsored by DLA Piper AustraliaJock McCormack and Jun Au lead off DLA Piper Australia’s monthly roundup by explaining the significance of the Full Federal Court overturning a decision concerning royalty withholding tax and diverted profits tax
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Sponsored by Wolters KluwerAmid legislative uncertainty, increased data challenges, and safe harbours laced with potential pitfalls, ITR hears some BEPS pillar two myths dispelled and learns how tax functions can get their preparations on track
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Sponsored by Lakshmikumaran & SridharanKaranjot Singh Khurana of Lakshmikumaran & Sridharan presents an Indian perspective on the transfer pricing implications of multinational corporations entering into global contracts that could affect group entities
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Sponsored by Vertex IncWith 45 states imposing a sales tax, Michael Bernard of Vertex explains the key points to note for European businesses aiming to broaden their market and capitalise on the e-commerce boom in the US
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia consider the Directorate General of Taxes’ increasing reliance on technology in transfer pricing evaluation, litigation developments in the area, resolution mechanisms, and mitigation strategies
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss Provisional Measure No. 1,227, which introduces new parameters for tax benefits and imposes significant limitations on the compensation of PIS and COFINS credits
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Sponsored by Ritch MuellerA change of president is not expected to alter the aggressive stance of the tax authorities, say Oscar López Velarde Perez, Juan José Paullada Eguirao, and Gabriel Márquez García of Ritch Mueller
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Sponsored by DeloitteThe insights of senior tax practitioners of Deloitte on recent practice in Argentina, Uruguay, Peru, and Colombia indicate an increasing amount of transfer pricing audit activity and a need for early preparation by taxpayers
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Sponsored by DeloitteRevised transfer pricing and permanent establishment compliance requirements are leading multinational corporations to consider the reorganisation of the maquiladora operating model through business restructuring, say Simón Somohano and Francisco Díaz of Deloitte S-LATAM
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Sponsored by DeloitteMario Coyoy of Deloitte S-LATAM and Michelle Martinelli of Deloitte Panama note increasing transfer pricing scrutiny in several Central American jurisdictions as they step up their attempts to enhance transparency and ensure compliance
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Sponsored by DeloitteVanesa Lanciotti of Deloitte Chile explains the country’s key transfer pricing-related measures as it seeks to increase its tax collection by 1.5% of GDP, with a new focus on tax compliance and financial governance
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Sponsored by Copper WolfLuis Carlos Pérez Gómez Ramírez and Víctor Hugo Bretado Fernández of Copper Wolf explain the context of a Mexican Supreme Court of Justice ruling concerning the revised approach to calculating statutory profit sharing distributions
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados discusses the new regulation concerning the declaration of tax benefits and the additional – and unnecessary – difficulties for taxpayers
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Sponsored by DeloitteCarlos Ayub of Deloitte Brazil focuses on the challenges for organisations that trade commodities under the country’s new transfer pricing legislation and explains what methods and courses of action are available to in-scope taxpayers
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Pietro Bricchetto of Gatti Pavesi Bianchi Ludovici examine the Italian tax authorities’ interpretative position concerning the VAT regime applicable to dispute financing services provided within the framework of third-party litigation funding agreements
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Sponsored by insightsoftwareJoin ITR and insightsoftware at 1pm BST (2pm CEST) on July 18 to hear how the gap between technology and finance can be addressed through transforming your tax processes and saying goodbye to disconnected systems
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Sponsored by Vieira de Almeida & AssociadosJoão Riscado Rapoula and Luís Maria of Vieira de Almeida & Associados conduct an in-depth analysis of the Portuguese and Angolan general anti-abuse rules, with a particular focus on the similarities and differences
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Sponsored by Lakshmikumaran & SridharanRaghavan Ramabadran, Charulatha Rajaji, and Raghav Rajeev of Lakshmikumaran & Sridharan conclude their analysis of goods and services tax litigation in India by explaining the critical importance of how pre-assessment or assessment proceedings are conducted
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Sponsored by Vieira de Almeida & AssociadosJoaquim Pedro Lampreia and Miguel Gonzalez Amado of Vieira de Almeida welcome the Portuguese Supreme Administrative Court’s clarification that a ‘pure’ holding company does not qualify for a stamp tax exemption on credit operations
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Sponsored by DLA Piper AustraliaUpdated build-to-rent tax concession proposals should encourage foreign investment, but the strict eligibility requirements will restrict the number of qualifying projects, say Jock McCormack and Eddie Ahn of DLA Piper Australia
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Sponsored by EY RomaniaMiruna Enache of EY Romania reports on the country’s bold introduction of a minimum turnover tax as its digital tax transformation continues apace, while the potential adoption of progressive taxation is still hotly debated
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Sponsored by GNV ConsultingIssues and opportunities arising from the tax facility for foreign loans and grants for government projects could be key to the ‘Golden Indonesia’ dream, say I Dewa Made Agung Nugraha and Egar Adipratama of GNV Consulting
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Sponsored by GNV ConsultingIndonesia aims to improve the efficiency of its commercial imports system and has issued several tax-related regulations in other areas recently, report I Dewa Made Agung Nugraha and Yoan Putra Muda of GNV Consulting
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services reports on a domestic ruling that draws on CJEU case law concerning the tax treatment of professional services provided by a company's board members
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente provide a guide to Italy’s transitional country-by-country reporting safe harbours for groups within the scope of the pillar two global minimum tax requirements
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Sponsored by Tax PartnerSilvan Guler and Thomas Zellweger of Tax Partner summarise Swiss collective investment schemes and their taxation, and assess the country’s appeal as an investment fund location after the introduction of limited qualified investor funds
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Sponsored by HLB ThailandPaul Ashburn, Amit Bhalla, and Urika Solano of HLB Thailand provide an update on Thailand’s progress towards implementation of BEPS 2.0 and explain why governmental agencies and multinational enterprises should undertake comprehensive reassessments
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Sponsored by Deloitte LuxembourgMultinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm’s-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg
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Sponsored by EY Asia-PacificSenior EY tax practitioners provide an update on the pillar two roll-out timetables across the region and consider various example scenarios as they assess the likely impact on multinational enterprises in 2024 and beyond
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Sponsored by Wolters KluwerIs your organisation sufficiently prepared for pillar two’s introduction? Join ITR and Wolters Kluwer at 2pm BST on June 18 2024 for a discussion on the key risks involved – and how to manage them
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Sponsored by KPMG SwedenAmanda Jern of KPMG Sweden says an annual tax transparency survey of 151 Nordic companies indicates reporting remains much the same, despite increasing pressure to report on tax
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Sponsored by KPMG ChinaLewis Lu of KPMG China looks at the recently passed Tariffs Law and the advancements in tax legislation
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici focus on how the simplified and streamlined approach set out in the OECD’s Pillar One – Amount B report enhances tax certainty
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Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosTaxation when companies acquire shares in entities that hold real estate can be a fiendishly complicated issue. Ricardo Seabra Moura of Morais Leitão, Galvão Teles, Soares da Silva & Associados summarises the regulations and interpretations
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Sponsored by DLA Piper AustraliaThe discontinuation of a proposed measure to deny deductions for certain payments relating to intangibles is among several taxation updates in Australia’s federal budget, as summarised by senior tax practitioners from DLA Piper Australia
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Sponsored by CuatrecasasAna Helena Farinha and Tiago Martins de Oliveira of Cuatrecasas provide an overview of the current status of the Portuguese warranty and indemnity insurance and tax insurance market
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Sponsored by MME Legal Tax ComplianceMarcel R Jung of MME Legal Tax Compliance explains the Swiss forfait tax regime, and cites the actor’s choice of his tax home as an indication of its long-standing attractiveness – and perhaps his fondness for fine chocolate
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente suggest what documentation can demonstrate the reasonableness of the costs of an intra-group transaction, and the benefits for a subsidiary
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Sponsored by GNV ConsultingBenjamin P Simatupang, Dwipa Abimanyu Dewantara, and Fajar Ramadhani of GNV Consulting highlight updated regulations and mandatory implementation of the Customs-Excise Information System and Automation 4.0 as Indonesia rings the changes
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Sponsored by DeloitteAs the need for integrated tax data increases, Jennifer Deutsch of Deloitte Global explains why a trifecta of strategic investment, training, and maintenance is the best bet for tax leaders aiming to generate real-time insights
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Sponsored by Lakshmikumaran & SridharanA multinational enterprise bearing the cost of an employee stock option plan granted to an Indian subsidiary creates several complexities, as explained by S Vasudevan, Harshit Khurana, and Sonali Bansal of Lakshmikumaran & Sridharan
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Sponsored by EY RomaniaAdrian Rus and Georgiana Bizdrigheanu of EY Romania explain the options for the country’s taxpayers in tackling double taxation and suggest how predictability and efficiency can be improved
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptWith transfer pricing principles becoming increasingly important as start-ups expand, Nouran Ibrahim and Maureen Guirguis of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the salient points and how to meet the challenges
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Sponsored by Ritch MuellerJuan José Paullada Eguirao and Gabriel Márquez García of Ritch Mueller explain the consequences of a foreign entity being deemed to have created a permanent establishment, and how to negate that risk
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Sponsored by Deloitte LuxembourgBalazs Majoros of Deloitte Luxembourg provides an update on the transfer pricing landscape in the grand duchy against a backdrop of opposition to a draft bill and winds of change from the EU
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Sponsored by Ritch MuellerThe interest of other FIBRAs in a potential acquisition of the Terrafina real estate investment trust highlights a lack of taxation guidance in such transactions, say Oscar López Velarde and Regina Albornoz of Ritch Mueller
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Sponsored by HLB ThailandStarting this year, Thailand’s Revenue Department has revised its approach to taxing foreign income received by tax residents. Paul Ashburn of HLB Thailand summarises the changes
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services welcomes a clear decision on how to categorise vouchers as the VAT treatment of such promotional schemes becomes ever more complex
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Sponsored by Lakshmikumaran & SridharanPrachi Bhardwaj and S Vasudevan of Lakshmikumaran & Sridharan explain how tax treaty provisions concerning the allowability of deductions for Indian residents align with non-discrimination clauses
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Luca Tortorella of Gatti Pavesi Bianchi Ludovici highlight two recent Italian tax court decisions regarding admissibility to mutual agreement procedures where the double taxation derives from self-adjustments rather than formal assessments
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Sponsored by KPMG GlobalDavid Linke of KPMG International and Victoria Heard of KPMG in the UK say it is imperative for tax leaders to understand geopolitical events and social trends to chart a course through choppy waters
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Sponsored by Vieira de Almeida & AssociadosMultinational enterprises that conduct intra-group transactions in EU jurisdictions should be closely monitoring a proposed transfer pricing directive, say João Velez de Lima and André Vilaça Ferreira of Vieira de Almeida
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Sponsored by Garrigues SpainThe Spanish Supreme Court has confirmed its stance on the fiscal year in which income from a refund of taxes should be recognised, report Alejandro Fernández and Sandra Díaz of Garrigues Spain
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Sponsored by EY RomaniaClaudia Sofianu and Dan Răuț of EY Romania explain a new initiative by the European Parliament that aims to address the rights and taxation of ‘gig’ workers, and consider its potential impact on Romania
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Sponsored by KPMG ChinaLewis Lu of KPMG China reviews the recent efforts to enhance tax certainty and enforcement effectiveness
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a significant addition to Italy’s case law on the application of transfer pricing regulations to interest-free loans between related parties
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Sponsored by DLA Piper AustraliaJock McCormack of DLA Piper Australia reports on a new initiative that aims to stimulate Australia’s build-to-rent sector and address housing supply challenges through the offering of tax concessions for construction and investment
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Sponsored by GNV ConsultingEndy Arya Yoga and Welly Armantha Napitupulu of GNV Consulting summarise recent updates in Indonesia’s tax system, including new debt-related guidelines in the customs and excise sectors and import policy changes
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados discusses a highly questionable manoeuvre by the Brazilian Federal Revenue Service to boost tax collection, despite a decision by the Federal Supreme Court
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Sponsored by CuatrecasasAndré Areias and Liliana Piedade of Cuatrecasas report on a preliminary ruling request by the Portuguese Arbitral Court and consider the decision’s expected impact on taxpayers
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Sponsored by Galicia AbogadosAn uptick in nearshoring activities in Mexico has led to heightened interest in trusts that specialise in energy and infrastructure investments. Federico Scheffler, Eduardo Espinosa, and Ileana García of Galicia Abogados explain the nuances
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Sponsored by DeloitteRalf Heussner, Anodri Suchdeve, and Fangying Xu of Deloitte examine the transfer pricing challenges arising from an increasing number of intra-bank funding arrangements as stricter capital requirements trigger the attention of regulators and tax authorities
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Sponsored by MDDPMonika Dziedzic and Łukasz Kumkowski of MDDP consider the dividend taxation exemption for payments made by Polish companies and explain the fulfilment of the beneficial ownership requirement by foreign holding companies
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Sponsored by KPMG ChinaLewis Lu and John Timpany of KPMG China report on the latest round of reviews of the EU’s list of non-cooperative jurisdictions for tax purposes, with Hong Kong now off the EU grey list
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Sponsored by Vertex IncTax and finance teams are adopting a working methodology pioneered by the tech world, says Peter Boerhof of Vertex
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Sponsored by Gatti Pavesi Bianchi LudoviciA case involving registration tax applied to a real estate contribution highlights the Italian tax framework’s inconsistency with the principles under a European directive, say Paolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on a bill of law presented by the Brazilian Congress that outlines a recently created ‘sin tax’ on goods and services considered harmful to health or the environment
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Sponsored by DeloitteGregory Verpoorten and Rogier Vanhorick of Deloitte explain three key lessons for tax leaders as real-time indirect tax compliance moves ever closer and compliance requirements become even more complex
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Sponsored by GNV ConsultingJeklira Tampubolon and Julius Wahyu Daryono of GNV Consulting Services report on fresh VAT incentives designed to stimulate investment in the housing sector, and several regulations that are intended to boost electric vehicle adoption
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Sponsored by DeloitteInterview with Carolina Acuña, partner, Deloitte S-LATAM
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Sponsored by DeloitteInterview with Asiata Agboluaje, Africa tax and legal international tax and regulatory partner (Nigeria), Deloitte Africa
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Sponsored by DeloitteInterview with Maria Trakadi, partner and tax and legal leader, Deloitte Greece
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Sponsored by KPMG ChinaLewis Lu of KPMG China explains the recently announced Hetao–Hong Kong zone income tax incentives, which aim to boost science and technology innovation, and stimulate investment and collaboration between Shenzhen and Hong Kong
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Sponsored by DeloitteInterview with Betsy Evans, US tax business services leader, Deloitte Tax LLP
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Sponsored by KPMG ChinaJoin ITR and KPMG China at 10am BST (5pm Beijing time) on April 18 2024 for an analysis of the tax treatment of indirect share transfers in China, and insights into potential developments
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explain the clarifications provided by the latest Indonesian transfer pricing regulation, but point out that uncertainty remains around several issues
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Sponsored by DeloitteInterview with Jo-Anne Anderson, partner, Deloitte Canada
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Sponsored by Vieira de Almeida & AssociadosJoaquim Pedro Lampreia and Carolina Telles Ferreira of Vieira de Almeida explain that Portugal’s tardiness in transposing the EU’s directive on administrative cooperation leaves online platform operators facing penalties through no fault of their own
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the first published statistics on the International Compliance Assurance Programme and their implications for businesses looking to obtain tax certainty
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Sponsored by Tax PartnerMonika Bieri and Daniel Schönenberger of Tax Partner AG analyse a recent Federal Administrative Court case and its implications for current transfer pricing practice in Switzerland
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Sponsored by Lakshmikumaran & SridharanIn the first article of a two-part series on goods and services tax litigation in India, Raghavan Ramabadran, Charulatha Rajaji, and Raghav Rajeev of Lakshmikumaran & Sridharan consider the requirements concerning pre-assessment proceedings
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Sponsored by YulchonWith South Korea expected to take a more aggressive approach to auditing, tax partners from Yulchon analyse four transfer pricing-related rulings that provide guidance for multinationals
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges
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Sponsored by Chevez Ruiz ZamarripaOscar Campero, Yoshio Uehara, and José Luis Iglesias of Chevez Ruiz Zamarripa provide a guide to the most commonly scrutinised concepts and the documentation required by the Mexican tax authority in transfer pricing audits
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Sponsored by DLA Piper AustraliaJason Carli of DLA Piper Australia analyses a Federal Court ruling on rollover relief, the publication of updates to a double tax agreement, and a report on amendments to the thin capitalisation reform bill
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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 the publication of guidelines concerning the compensation of asset managers that provide services to entities within the same group
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services provides an update on the latest developments as Spain maintains its slow but steady progress towards the digitalisation of the invoicing function
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Sponsored by Ikeyi Shittu & Co.As the Nigerian government aims to boost its tax revenue, Taofeek ’Bola Shittu of Ikeyi Shittu & Co. explains how to minimise the risk of additional tax liability resulting from non-compliance with transfer pricing regulations
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Sponsored by GNV ConsultingCharles Setia Oetomo, Felic Setiawan, and Gomgom Johannsen Kevan of GNV Consulting provide a guide to Indonesia’s new transfer pricing regulation, what to expect, and how taxpayers may prepare for its application
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Sponsored by DDTC ConsultingTami Putri Pungkasan and Yurike Yuki of DDTC Consulting say an Indonesian transfer pricing update recognises the prevention of double taxation as a purpose and not merely as a means to prevent tax avoidance
