Taxand
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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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Sponsored by TaxandSenior tax practitioners from five member firms of the Taxand network provide insights into enhanced tax audit scrutiny of transfer pricing in their jurisdictions and suggest several means of recourse for taxpayers
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The firm also won regional awards for Pro Bono Firm of the Year and Tax Law Firm of the Year
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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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Vittoria Segre, partner at CMS Italy, reviews a range of TP topics discussed at the event, including financial transaction audits and permanent establishment issues
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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 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 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 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 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 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 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 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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Wopke Hoekstra takes tax hotseat in new EU Commission; in other news, Latham boosts energy tax expertise and Fieldfisher expands Spanish tax practice
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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