Firm
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 Australian senator told ITR that PwC is still trying to manage the saga as a PR issue rather than a systemic problem
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
Sponsored
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Sponsored by DeloitteShaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space
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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
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Sponsored by DeloitteMariusz Każuch, Inka Traeger, and Conrad Marburg of Deloitte consider tax authorities' recharacterisation of intercompany transactions through drawing on recent practice in Poland and Germany, and suggest proactive measures global businesses can take
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Sponsored by DeloitteVrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved
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Sponsored by DeloitteAaron Wang, Carlo L Navarro, and Rebecca Cook of Deloitte explain several Asia-Pacific jurisdictions’ differing approaches towards the construction of an arm’s-length range amid the shifting contours of the region’s transfer pricing landscape
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Sponsored by DeloitteCarlos Serrano Palacio, Richie Lombard, and Bernardo Misle of Deloitte analyse recent measures to resolve tax uncertainty in a climate of increasing transfer pricing audits and controversy, and consider what further steps should be taken
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Sponsored by DeloitteWith the pricing of intangibles laced with difficulty, Ishan Maini, Eric Linge, and Richard Schmidtke of Deloitte draw on two cases in Germany and Israel revolving around differing interpretations concerning the delineation of transactions
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Sponsored by DeloitteThe complex distinction between legal ownership and economic ownership of intangible assets means multinationals must take proactive measures to avoid transfer pricing controversy, say Christine Ramsay, Jordi Morera, and Marguerite Mei of Deloitte
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Sponsored by DeloitteMultinationals attempting to avoid and mitigate penalties potentially arising from transfer pricing controversy could take a tip from standard exam advice. Eddie Morris and Aydin Hayri of Deloitte explain the importance of recording actions
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Sponsored by DeloitteNicola Lostumbo and Jie Pan of Deloitte provide insights into high-value intercompany service charges, their role in creating value, and the most common tax authority challenges, before concluding with some considerations in mitigating risks
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Sponsored by KPMG SwedenÅsa Edesten and Mazlum Yildiz of KPMG Sweden say there remains a lack of clear legal precedent on the impact of ‘control over risk’ in assessing contractual terms between related parties, despite a recent ruling
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Sponsored by Tax SystemsJoin Tax Systems at 11am BST (12pm CEST) on October 17 to hear how transfer pricing documentation and processes can be managed more effectively in the face of enhanced scrutiny by tax authorities
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The head of Skadden’s European tax practice said the recent Apple CJEU ruling could be the last of its kind as pillar two develops
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptWhile the rule could result in enhanced tax revenues, Egypt must consider its effect on foreign direct investment, say Rabie Morsy, Karim Adel, and Sandra Aziz of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt
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The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours
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On a panel of advisers and tax authority representatives from a range of European jurisdictions, financial transactions were pinpointed as a key TP audit focus
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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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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
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The lack of provision for bilateral advance pricing agreements is a notable omission from proposed reforms of Brazil’s transfer pricing rules
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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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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
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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
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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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The court overturned a common and well-established position of the Italian tax authorities in a highly significant ruling, experts have told ITR
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Both hires have extensive experience working for EY in the US
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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 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 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 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 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 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 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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Mariani, global head of tax disputes at KPMG’s Netherlands arm, also outlined various dispute resolution strategies in an exclusive ITR interview
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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 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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Legal battles involving the IRS, HMRC and ATO feature as companies have been ordered to pay vast sums
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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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Work on the publication was co-funded by several European governments and the EU
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Vortex Capital Partners will become a majority shareholder in TP Tuned, which specialises in TP documentation
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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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Olga Trifonova began her new leadership role on July 1
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The oral hygiene company is already fighting off a separate $20.4m TP demand from last year
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ITR is delighted to reveal all the shortlisted nominees for the 2024 Americas Tax Awards
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Consensus on the amount A multilateral convention will take more than six months to achieve, one expert believes
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ITR is delighted to reveal all the shortlisted nominees for the 2024 Europe Middle East & Africa Tax Awards
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ITR is delighted to reveal all the shortlisted nominees for the 2024 Asia-Pacific Tax Awards
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There is a 'critical need' for a unified platform to address challenges in TP, the organisation’s president told ITR
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Canada risks inflaming US trade relations in a presidential election year and increasing costs for consumers, according to local experts
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Singapore faces controversies with many trade partners and needs to constantly keep tax guidelines up to date, a local tax expert told ITR
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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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PepsiCo succeeded by applying TP principles and employing ‘proper advisers’ in the appeal, one expert tells ITR
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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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But consenus achieved on 'vast majority' of issues and countries are 'still at the table', the OECD says
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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 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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While taxpayers fear unilateral measures in the event of no amount A agreement, it is likely the talks will continue until consensus is reached
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The ruling for PwC’s client is a blow for the ATO and its ability to tax multinationals on complex cross-border transactions
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As German clients attempt to comply with complex cross-border rules, local advisers argue that aggressive tax authorities are making life even harder
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There will always be multinationals trying to minimise tax by pushing the boundaries of their cross-border arrangements, Rob Heferen claimed
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Argentina, Brazil, Mexico and South Africa are among the countries the OECD believes could benefit from the simplified TP rules
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However, making APAs harder to reach could ‘pose problems’ for UK businesses
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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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Making cross-border purchases can save on VAT in the short term but TP issues may arise, an in-house tax expert suggested
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More than 145 countries have now signed up to the deal since it was introduced in 2021
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AI will speed up some of the most laborious TP processes without making human input redundant, argues Hank Moonen, CEO of TaxModel
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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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Authorities must ensure that Russian firms do not use transfer pricing schemes to increase profits made from oil sold in different markets, advocacy organisations have argued
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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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The OECD has revealed little about the progress of the talks on pillar one since February
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The Australian Taxation Office scored a victory over the company last year in a case that will be closely watched by other multinationals
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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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The US is capitalising on a fertile deals market to take centre stage in tax talent recruitment, according to insights from ITR+’s Talent Tracker
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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 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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Proposed regulations on corporate excise tax pose challenges on different fronts, experts tell ITR
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The finalists for the 13th annual awards have been revealed
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Mazars needs to do all it can to capitalise on TP as a growth area, ex-Deloitte TP director Jeremy Brown has told ITR
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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 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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Luis Coronado suggests companies should embrace technology to assist with TP data reporting, as the ‘big four’ firm unveils a TP survey of over 1,000 professionals
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The proposed matrix will help revenue officers track intra-company transactions from multinationals
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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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The new, fully integrated office will also offer M&A, dispute resolution, IP and corporate tax services
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The new tech partnership will assist clients worldwide with pillar two; in other news, UK accountancy firm MHA completes a regional merger
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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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The retail pharmacy chain owner ‘intends to vigorously defend’ its TP position
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Jeremy Brown arrives at the firm after a near 16-year career with Deloitte
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Their prediction comes after the IRS announced it would send compliance letters to large foreign companies emphasising their US tax obligations
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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 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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The appeal related to deductions claimed by the Singaporean telecoms company, which was advised by PwC, on a A$5.2 billion acquisition from 2002
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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 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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Rob Clary observed that clients ‘have an expectation you can operate globally’ and that Baker McKenzie is well positioned to meet the demand
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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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Experts from TP tech provider Aibidia also warned ITR that companies ignoring pillar two is a ‘huge issue’ and a ‘red flag’
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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
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Amount B is meant to increase simplicity and reduce uncertainty, but US TP specialists claim it may lead to controversy
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Sponsored by Skeppsbron SkattIngrid Faxing and Henri Ahtiainen of Skeppsbron Skatt analyse a proposal to incorporate the OECD Transfer Pricing Guidelines into EU law and question whether it will become a reality after several objections
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Barbara Voskamp is bullish on hiring local talent to boost DLA Piper’s Singapore practice, and argues that ‘big four’ accountants suffer from a stifled creativity
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Sponsored by Deloitte CanadaRalf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte conclude their summary of an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration
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But the US tax agency’s advice is consistent with OECD guidance and shouldn’t surprise anyone, other experts tell ITR
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Sponsored by insightsoftwareJoin ITR and insightsoftware at 2pm GMT (3pm CET) on March 20 2024 to hear about the increased reporting complexities introduced by pillar two and how to navigate them through efficient management of data
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The report is aimed at helping 'low-capacity countries', the OECD has claimed
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptIn the first article of a two-part series on transfer pricing audits in Egypt, Yasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the current process
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptYasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt conclude a two-part series on transfer pricing audits in Egypt by anticipating the changes under the newly established automated process
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However, ICAP may not provide the legal certainty of an APA and tax authorities will have limited capacity, experts argue
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Sponsored by Deloitte CanadaRalf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte reveal further insights from an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration
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Sponsored by GNV ConsultingFabian Abi Cakra and Danang Syailendra of GNV Consulting explain how several Indonesian transfer pricing regulations have been combined into new legislation, and summarise changes to employee income tax under a withholding tax regulation
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Sponsored by DeloitteInterview with Chris Atkinson, partner, tax and legal, Deloitte Australia
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Sponsored by DeloitteInterview with Eric Lesprit, partner, transfer pricing, Deloitte Société d’Avocats, France
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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 revised timeframes and requirements for Italian taxpayers submitting transfer pricing documentation and aiming to benefit from the penalty protection regime
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Sponsored by DLA Piper AustraliaJun Au and Jock McCormack of DLA Piper Australia provide an update on several significant pieces of draft legislation concerning the petroleum resource rent tax and related matters
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The firm has continued its expansion efforts by raiding from the ‘big four’ once more
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Sponsored by DeloitteA three-part weekly series begins with Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte sharing insights from an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration
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Sponsored by KPMG ChinaLewis Lu and Xiaoyue Wang of KPMG China consider issues with conducting year-end transfer pricing adjustments in China
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Tax advisers can’t afford to ignore cryptocurrency if they want deeper client relationships, argues Pretino Albury of Kreston Global
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Sponsored by Deloitte CanadaRalf Heussner, Alison Lobb, and Yvonne Weigelt from Deloitte’s global transfer pricing network preview a series based on an interview with the head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration
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The ‘big four’ firm hopes the new technology will make client service more efficient, while Pinsent Masons has appointed a new tax head in Dublin
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There is definitely a role for ICAP in TP compliance for multinational enterprises, a TP leader told ITR
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Sponsored by Deloitte CanadaYong Chan Lee and Eun Jin Choi of Deloitte Korea provide an update on the application of the OECD’s two-pillar solution and explain how Korean businesses can prepare for amount B’s introduction
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptNouran Ibrahim and Haidy Elaasser of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain what supporting evidence should be kept in readiness for potential queries raised by the Egyptian Tax Authority at times of audit
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Sponsored by DeloitteSanjay Kumar and Suchint Majmudar of Deloitte India provide a guide to the BEPS package and explain why streamlining the calculation of amounts A and B is integral to its successful implementation
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The letters don’t reflect final determinations that the taxpayer has underpaid US taxes, tax experts argue
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RSM’s European leader tells ITR of surging pillar two client demands and capitalising on disillusioned talent from the ‘big four’
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Compliance alerts have been sent to more than 180 subsidiaries of large foreign corporations, emphasising their US tax obligations
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HM Revenue and Customs has received warnings from consultation respondents including the ‘big four’
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Sponsored by Deloitte LuxembourgDinko Dinev and Ismail Candan of Deloitte Luxembourg explain how tailored transfer pricing policies can underpin success as the increasing complexity of debt investment instruments and heightened regulatory oversight demand enhanced tax compliance measures
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The international firm’s new addition will also provide corporate, indirect tax compliance and dispute resolution services
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Dispute resolution, TP compliance costs and the proposal’s consistency with OECD principles have all come under the microscope
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt
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The Dutch Ministry of Finance no longer considers the UAE a low-tax jurisdiction, while 2024 marks the start of new roles for tax partners
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Transfer pricing, alleged tax fraud and disputes over back taxes all feature in this year’s ITR list of tax cases to watch
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The US Internal Revenue Service could consider a company’s membership in a corporate group when deciding on an interest rate for an intragroup loan extended to the firm
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To avoid ambiguities, interpretation difficulties and possible conflicts, the directive should stay as close as possible to OECD guidelines, the tax group has recommended
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Michael Puls will start at the ‘big four’ firm on January 2 2024, servicing clients both domestically and internationally
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Sponsored by KPMG USMultinational companies face numerous year-end tasks but should not forget to file the treaty notifications that are required in certain US tax treaties, say senior tax practitioners from KPMG in the US
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Sponsored by EY Asia-PacificMultinationals importing goods in the APAC region face varying compliance requirements across the jurisdictions. Shubhendu Misra and Michiel Friedhoff of EY explain several approaches to managing and avoiding disputes with the customs authorities
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EU member states are exclusively competent to define their national tax rules, the Court of Justice of the EU has ruled in a case concerning Amazon
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Amount B promises to streamline a fundamental TP issue but unresolved issues remain, accountancy institutes have argued
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Sponsored by Crowe Valente/Valente Associati GEB PartnersCarola Valente of Crowe Valente/Valente Associati GEB Partners explains the application of the OECD Transfer Pricing Guidelines to financial transactions as multinationals increasingly centralise their treasury functions
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Politicians may feel entitled to an explanation of Microsoft’s TP strategy following the IRS’s probe, but whether they receive it is another question, a senior tax expert warns
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The European Commission hasn’t sufficiently justified certain choices and there should be a stronger TP role for the European Parliament, a politician has claimed
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The metal multinational’s victory, in a case worth $12 million, continues the trend of companies coming out on top against India’s revenue department
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US analyse the 2022 mutual agreement procedure statistics for the US and discuss their significance for businesses
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptNouran Ibrahim and Hana Khalil of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt discuss the rationale and basics of implementing mechanisms for the correct administration of central/intra-group service charges
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The order comes amid controversy over another of David Collard’s companies’ tax and TP affairs
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NASSCOM, which represents over 3,000 Indian companies, has argued for the removal of the segmentation rule
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ITR invites tax firms, in-house teams, and tax professionals to make nominations for the 2024 ITR Tax Awards in the Americas, EMEA, and Asia-Pacific
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More people working on transfer pricing disputes and treating cases seriously may contribute to the country’s speedy process, Sandra Knaepen suggests to ITR
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The CJEU advocate general’s opinion represents a shift in Apple’s EU state aid litigation but experts argue the saga isn’t over
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The Netherlands took the shortest amount of time to close transfer pricing cases, beating Switzerland and Denmark to the award
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The tribunal rejected the revenue department's appeal in a transfer pricing case related to the 2004-05 assessment year
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Sponsored by CuatrecasasAna Helena Farinha and Tiago Martins de Oliveira of Cuatrecasas say that the intragroup financing of Portuguese companies could be affected by a rule that is out of kilter with several other EU jurisdictions
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The European Commission experts responsible for TP legislation say the proposed rules have been well-received by businesses
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The ruling undermines Coca-Cola’s challenge in a dispute which is the final part of a $3.4 billion TP case
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Specific schedules for bauxite and lithium aim to bring a transfer pricing value uplift to developing countries, OECD expert Andrew Viola tells ITR
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Sponsored by Crowe Valente/Valente Associati GEB PartnersCarola Valente of Crowe Valente/Valente Associati GEB Partners explains why ESG goals and requirements are intertwined with transfer pricing, and how multinationals can mitigate the associated risks throughout value chains
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A regulatory board is understood to have cleared the acquisition of PwC Australia's former government consulting wing
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The proposal will add to political disagreements over the international tax system, policy guru Adam Michel has argued
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The oral hygiene company intends to address the order through alternative dispute resolution
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His selection comes after US head Tim Ryan’s exit from the firm despite being a top contender for the role
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Panellists clashed on pillar one in particular, with a tax reformist saying the project is like ‘a pillar of ice that has been left in the sun too long’
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A new discussion has opened at the UN on how the arm’s-length principle works in the context of two important industries
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New guidance on TP regulation is welcome but flaws remain, according to local tax experts
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Taxpayers have more time to analyse the impact of the new rules but disputes are likely, according to counsel
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners report on a decision regarding the taxation of intercompany transactions based on the activities of a branch and its parent company
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The company doesn’t agree with historical adjustments amid a dispute that mainly concerns transfer pricing.
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Low- and middle-income countries are expected to gain the most as a share of corporate income tax revenues, the OECD has claimed.
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Sponsored by Deloitte LuxembourgKarolina Ibranyi-Matkovits and Michal Stepien of Deloitte Luxembourg summarise crucial research on how debt capacity is managed across Europe, and outline how taxpayers are building sustainable positions.
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Conversations with tax officials could run more efficiently if they had more expertise, a senior TP figure suggested at an ITR conference in London.
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Sponsored by Deloitte LuxembourgJoin ITR and Deloitte Luxembourg at 4pm CET (3pm GMT, 10am EST) on November 9 2023 to hear about strategies to effectively manage transfer pricing controversy, and the latest market developments in the area of financial transactions transfer pricing.
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A senior tax figure took aim at the OECD’s recent record on creating simplicity through its policy proposals, at an ITR conference in London.
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PwC publishes detailed accounts of its behaviour in the tax scandal in Australia, while another tax trial looms for pop star Shakira.
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptSenior figures from Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt comment on the explanatory guide issued by the Egyptian Tax Authority regarding the application of TP rules in the country.
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The winners of the ITR Europe, Middle East, and Africa Tax Awards 2023 have been announced!
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The winners of the ITR Asia-Pacific Tax Awards 2023 have been announced!
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Mauro Faggion appeared cautiously optimistic as the European Commission waits to see whether all 27 member states will accept its proposal.
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The global minimum rate also won’t entirely stop a race to the bottom, according to a tax director speaking at an ITR conference in London.
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Sponsored by DeloitteAaron Wang of Deloitte China and Iva Georgijew of Deloitte Poland set out the key questions when limited risk and low-risk distributors incur losses, and consider the challenges presented in several common scenarios.
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Sponsored by DeloitteVrajesh Dutia of Deloitte India and Jennifer Breeze of Deloitte UK assess the complex arm’s-length decisions that global businesses had to make during the COVID-19 pandemic, and the various responses from international tax authorities.
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Sponsored by DeloitteEdward Morris of Deloitte UK and Sobhan Kar of Deloitte India question whether the adage that mutual agreement procedures work, but too slowly, is still correct.
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Sponsored by DeloitteFroukje Frerichs, Stefano Lavore, and Nicola Lostumbo of Deloitte provide a guide to the most common tax authority challenges in the business restructuring context and present a three-pronged approach to mitigating this risk.
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Sponsored by DeloitteGeoff Gill of Deloitte Australia and Andrew Skipsey of Deloitte UK analyse the use of profit split transfer pricing methods in the rapidly evolving banking and commodity trading businesses.
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Sponsored by DeloitteSimón Somohano and Francisco Díaz of Deloitte S-LATAM explain the changes for maquiladoras after the repeal of advance pricing agreements as a compliance option and the implications for Mexico’s competitiveness as a manufacturing location.
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Sponsored by DeloitteAriel Krinshpun and James Mahon, III of Deloitte US and George Galumov of Deloitte Switzerland analyse two areas of intercompany financing arrangements as transactions come under increasing scrutiny from tax authorities.
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Sponsored by DeloitteKirsti Longley of Deloitte Tax LLP and Carlos Serrano Palacio of Deloitte Spain explain the benefits of advance pricing agreements in managing transfer pricing exposure, and the pros and cons of unilateral and bilateral advance pricing agreements.
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Sponsored by DeloitteChristine Ramsay and Samer Wani of Deloitte Canada and Subhabrata Dasgupta of Deloitte Malaysia highlight significant legislative developments in several jurisdictions as the world strives to keep pace with the OECD's Transfer Pricing Guidelines.
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Sponsored by DeloitteITR has collaborated with Deloitte TP experts from around the globe to examine the latest controversies in this ever-changing aspect of the tax landscape.
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The country’s tax authorities are not interested in seeing transfer pricing studies any more, it was claimed at an ITR industry conference in London.