Speaking exclusively at ITR’s Transfer Pricing Forum in Europe, the Commission’s Marc Clercx also addressed industry concerns over the arm’s-length principle
White & Case’s tax controversy head discusses how to stop a dispute before it starts and shares insights from a significant TP case with the IRS
The court overturned a common and well-established position of the Italian tax authorities in a highly significant ruling, experts have told ITR
Both hires have extensive experience working for EY in the US
Sponsored
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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
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente report on a ruling by the Italian Tax Agency and explain an update to the deadline for the submission of income tax returns
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Sponsored by DeloitteJobst Wilmanns and Anodri Suchdeve of Deloitte Germany introduce this year’s ITR guide presenting transfer pricing insights across several industries, with analysis from Deloitte’s transfer pricing industry experts and factoring in global economic changes
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Sponsored by DeloitteClaudia Lauten, Janis Sussick, and Karen Smolka of Deloitte discuss how amount B could impact the tax and transfer pricing approaches of global multinational enterprises in the industrial products and construction sector
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Sponsored by DeloitteGeoff Gill and Michael Manser of Deloitte Australia provide a guide to the upcoming public country-by-country reporting measures and how multinationals in the financial services sector should prepare for the first year of reporting
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Sponsored by DeloitteRichard Schmidtke, Heike Schenkelberg, and David Sauer of Deloitte Germany analyse the impact of specific characteristics of the life sciences and healthcare industry on the applicability of amount B
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Sponsored by DeloitteIshan Maini of Deloitte UK and Jay Das of Deloitte US say the need for technology, media, and telecommunications companies to analyse the risks associated with intercompany transactions has never been greater
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Sponsored by DeloitteWith ever-increasing challenges in the wholesale and retail industry, senior tax practitioners at Deloitte Germany consider the impact of amount B on the profit allocation of multinationals operating in the sector
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Sponsored by DeloitteRalf Heussner of Deloitte Japan and Aaron Lee of Deloitte Singapore examine the latest transfer pricing trends impacting the banking sector in view of the implementation of the new Basel accord from 2025
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Sponsored by DeloitteJobst Wilmanns and Anodri Suchdeve of Deloitte preview a guide to the latest transfer pricing trends, produced in collaboration between ITR and global transfer pricing industry experts from Deloitte
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Sponsored by HLB ThailandAmit Bhalla and Andrew Jackomos of HLB Thailand explain the Thai Revenue Code’s guidance in determining the nature of the relationship between two entities and whether transfer pricing disclosure forms are required
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Crowe Valente/Valente Associati GEB Partners consider the ramifications of a ruling concerning the inclusion of loss-making companies in a transfer pricing benchmarking analysis as comparable entities
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Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services reports on a pronouncement by an EU member state on the impact that transfer pricing adjustments have on the VAT applied to transactions
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Sponsored by Lakshmikumaran & SridharanKaranjot Singh Khurana of Lakshmikumaran & Sridharan presents an Indian perspective on the transfer pricing implications of multinational corporations entering into global contracts that could affect group entities
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia consider the Directorate General of Taxes’ increasing reliance on technology in transfer pricing evaluation, litigation developments in the area, resolution mechanisms, and mitigation strategies
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Sponsored by DeloitteThe insights of senior tax practitioners of Deloitte on recent practice in Argentina, Uruguay, Peru, and Colombia indicate an increasing amount of transfer pricing audit activity and a need for early preparation by taxpayers
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Sponsored by DeloitteRevised transfer pricing and permanent establishment compliance requirements are leading multinational corporations to consider the reorganisation of the maquiladora operating model through business restructuring, say Simón Somohano and Francisco Díaz of Deloitte S-LATAM
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Sponsored by DeloitteMario Coyoy of Deloitte S-LATAM and Michelle Martinelli of Deloitte Panama note increasing transfer pricing scrutiny in several Central American jurisdictions as they step up their attempts to enhance transparency and ensure compliance
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Sponsored by DeloitteVanesa Lanciotti of Deloitte Chile explains the country’s key transfer pricing-related measures as it seeks to increase its tax collection by 1.5% of GDP, with a new focus on tax compliance and financial governance
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Sponsored by DeloitteCarlos Ayub of Deloitte Brazil focuses on the challenges for organisations that trade commodities under the country’s new transfer pricing legislation and explains what methods and courses of action are available to in-scope taxpayers
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Sponsored by Deloitte LuxembourgMultinational enterprises must include transfer pricing and cost accounting experts in taking an integrated approach to supporting the arm’s-length nature of intragroup service charges, say Enrique Marchesi-Herce, Gilles Andreini, and Serena Picariello of Deloitte Luxembourg
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici focus on how the simplified and streamlined approach set out in the OECD’s Pillar One – Amount B report enhances tax certainty
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente suggest what documentation can demonstrate the reasonableness of the costs of an intra-group transaction, and the benefits for a subsidiary
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Sponsored by Lakshmikumaran & SridharanA multinational enterprise bearing the cost of an employee stock option plan granted to an Indian subsidiary creates several complexities, as explained by S Vasudevan, Harshit Khurana, and Sonali Bansal of Lakshmikumaran & Sridharan
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Sponsored by EY RomaniaAdrian Rus and Georgiana Bizdrigheanu of EY Romania explain the options for the country’s taxpayers in tackling double taxation and suggest how predictability and efficiency can be improved
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptWith transfer pricing principles becoming increasingly important as start-ups expand, Nouran Ibrahim and Maureen Guirguis of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the salient points and how to meet the challenges
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Sponsored by Deloitte LuxembourgBalazs Majoros of Deloitte Luxembourg provides an update on the transfer pricing landscape in the grand duchy against a backdrop of opposition to a draft bill and winds of change from the EU
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Luca Tortorella of Gatti Pavesi Bianchi Ludovici highlight two recent Italian tax court decisions regarding admissibility to mutual agreement procedures where the double taxation derives from self-adjustments rather than formal assessments
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Sponsored by Vieira de Almeida & AssociadosMultinational enterprises that conduct intra-group transactions in EU jurisdictions should be closely monitoring a proposed transfer pricing directive, say João Velez de Lima and André Vilaça Ferreira of Vieira de Almeida
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a significant addition to Italy’s case law on the application of transfer pricing regulations to interest-free loans between related parties
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Sponsored by DeloitteRalf Heussner, Anodri Suchdeve, and Fangying Xu of Deloitte examine the transfer pricing challenges arising from an increasing number of intra-bank funding arrangements as stricter capital requirements trigger the attention of regulators and tax authorities
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explain the clarifications provided by the latest Indonesian transfer pricing regulation, but point out that uncertainty remains around several issues
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the first published statistics on the International Compliance Assurance Programme and their implications for businesses looking to obtain tax certainty
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Sponsored by Tax PartnerMonika Bieri and Daniel Schönenberger of Tax Partner AG analyse a recent Federal Administrative Court case and its implications for current transfer pricing practice in Switzerland
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Sponsored by YulchonWith South Korea expected to take a more aggressive approach to auditing, tax partners from Yulchon analyse four transfer pricing-related rulings that provide guidance for multinationals
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges
Mariani, global head of tax disputes at KPMG’s Netherlands arm, also outlined various dispute resolution strategies in an exclusive ITR interview
Legal battles involving the IRS, HMRC and ATO feature as companies have been ordered to pay vast sums
Work on the publication was co-funded by several European governments and the EU
Vortex Capital Partners will become a majority shareholder in TP Tuned, which specialises in TP documentation
Olga Trifonova began her new leadership role on July 1
Consensus on the amount A multilateral convention will take more than six months to achieve, one expert believes
There is a 'critical need' for a unified platform to address challenges in TP, the organisation’s president told ITR
Singapore faces controversies with many trade partners and needs to constantly keep tax guidelines up to date, a local tax expert told 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.
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
The finalists for the 13th annual awards have been revealed