The court emphasised that TP analysis must adhere to the arm's-length principle, be based on the specific facts of each transaction and comply with domestic regulations, one expert says
Gilles Roth, speaking at the Luxembourg Transfer Pricing Association’s launch event, also said that his country is ‘carefully considering’ the implementation of amount B
The ruling in January was the first time the court had unanimously upheld a taxpayer's position in a case concerning TP, according to a lawyer who worked on the case
The change is understood to include enhancing information comparison
Sponsored
Sponsored
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Sponsored by EXA AGExplore the opportunities now available to achieve automated segmentation, forecasting, and price-setting – including alignment with customs value – in a webinar held in partnership between ITR and EXA AG on May 13 at 3pm BST (10am EDT, 4pm CEST) -
Sponsored by DeloitteDoris Gichuru, Africa Tax & Legal transfer pricing partner (Kenya), Deloitte Africa
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptNouran Ibrahim and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt say taxpayers required to submit transfer pricing documentation could avoid penalties by acting in response to a recently published law
Taxpayers that operate internationally need to be better prepared for increased tax and TP scrutiny, one expert tells ITR
An OECD webinar on amount B also heard that a distributor’s compliance certifications could potentially move them out of scope
The appointment of ex-PwC partner Abhijit Ghosh follows that of ex-EY partner James Badenach as head of A&M Tax for APAC last year
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
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
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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