The proposed Block TP Assessment could provide taxpayers with long-term arm’s-length price certainty and reduce admin headaches, Sanjay Sanghvi of Khaitan & Co writes
From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025
Despite a three-year-high in tax revenues generated from settling TP cases, HMRC reported a sharp fall in resolved MAP disputes
Donald Trump’s inauguration, pillar two, APAs and TP were all up for discussion as ITR spoke to Baker McKenzie’s two newly minted US partners
Sponsored
Sponsored
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Sponsored by KPMG SwedenÅsa Edesten, Fredrika Wendleby, and André Alcén of KPMG Sweden highlight that the Swedish Tax Agency is refusing reassessments for downward transfer pricing adjustments, thereby causing legal uncertainty for multinational enterprises -
Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain how an Italian Supreme Court ruling clarifies the evidentiary burdens and arm’s-length compliance
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Sponsored by DeloitteInterview with Dr Alexander Linn, partner, business tax
Baker McKenzie’s survey of 600 corporate counsel also found that global employee mobility issues were a key driver of tax controversy
Multinationals will continue to shift profits out of Slovakia to EU member states despite pillar two’s implementation, according to the report
ITR’s most interesting stories of the year covered ‘landmark’ legal battles, pillar two, AI’s relationship with transfer pricing and more
The tool, which will automatically compute amount B returns, requires “only minimal data inputs”, according to the OECD
The rules are intended to implement the substance of an earlier OECD report in its entirety
Aibidia said the IBFD collaboration will benefit TP professionals through more robust risk assessments and compliance planning
But advisers also suggest that the proposals may lead to increased compliance costs and obligations
A high number of granted APAs demonstrates the Italian tax authorities' commitment to resolving TP issues proactively, experts say
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Opinion: Republicans risk more than they realise by opposing OECD
Conservative US politicians are building a narrative against the OECD’s two-pillar plan for international tax reform, but they have no serious alternative vision. -
Opinion: Biden could save pillar one, but there’s a catch
The OECD must pay attention to US politics because the next election could determine whether the country will make or break international tax reform. -
Opinion: Pillar one might already be doomed
The OECD’s plan to reform transfer pricing rules and international taxing rights still has to reckon with US uncertainty. -
ChatGPT is more opportunity than threat for tax leaders
Russell Gammon, chief solutions officer at Tax Systems, makes the positive case for AI in tax. -
ITR Summer Issue 2023: Editorial
ITR’s latest quarterly PDF is going live today, leading on the PwC Australia tax leaks scandal and its fallout for tax advisers.
Awards
ITR invites tax firms, in-house teams, and tax professionals to make nominations for the 2025 ITR Tax Awards in the Americas, EMEA, and Asia-Pacific
Awards
The firm also won regional awards for Pro Bono Firm of the Year and Tax Law Firm of the Year
Awards
The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2024 Americas Tax Awards