The new guide also covers transfer pricing and states that all transactions between related parties must be at arm’s-length
Clients of audit services should also be disallowed access to firms’ other services, it was claimed; in other news, Ireland approves amount B
The ruling follows the Federal Court of Australia’s full court deciding in favour of the soft drink company in June
Sweeping changes are headed for Germany’s TP system in the New Year. Tax teams will need to be well-prepared, say Andreas Katz and Anna Kupprion of Kreston Bansbach
Sponsored
Sponsored
-
Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a transfer pricing-related ruling by the Italian Supreme Court that effectively clarifies the role of OECD guidelines and the ‘best method’ rule -
Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptNouran Ibrahim and Karim Adel of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt say mutual agreement procedures will have a vital role to play as the country modernises its tax infrastructure
-
Sponsored by Deloitte LuxembourgDinko Dinev and Adam Wojewoda of Deloitte Luxembourg explore AI’s potential to enhance efficiency in transfer pricing but emphasise the irreplaceable value of human expertise in navigating complex regulatory landscapes
Thin capitalisation rules limit the amount of debt deductions that can be claimed but regard must also be given to other income tax law provisions, the ATO said
The move will provide certainty to taxpayers and reduce the risk associated with pricing transactions for TP, according to India’s Ministry of Finance
Nigeria is pondering the adoption of pillar two despite rejecting it in the past, local experts also suggest
The memorandum raises concerns and taxpayer challenges should be expected, four experts tell ITR
The committee is deciding whether to add the appendix to existing guidance for tax administrations when scrutinising MNE activities
Meanwhile, African revenue authorities expect their next taxable income to come from TP and from a larger share of the global tax bill, one expert tells ITR
HMRC is 'showing us what good looks like', one expert has claimed
The firm also won regional awards for Pro Bono Firm of the Year and Tax Law Firm of the Year
-
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.
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