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
Sponsored
Sponsored
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici discuss the latest developments in the OECD International Compliance Assurance Programme and evaluate its role within the framework of tax certainty -
Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain the conditions that transfer pricing documentation must satisfy to allow taxpayers to benefit from Italy’s penalty protection regime concerning hybrid mismatches
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Sponsored by KPMG SwedenThomas Andersson and Tobias Almqvist of KPMG Sweden discuss a Supreme Administrative Court ruling affirming the right to judicial review of corresponding adjustments under tax treaties, ensuring legal remedies for double taxation disputes
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
Approximately 74% of MAP cases in 2023 reached a full resolution, but new transfer pricing MAP cases fell by 16%
The new guide also covers transfer pricing and states that all transactions between related parties must be at arm’s-length
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
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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