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Lesley Holstead, former tax controversy and transfer pricing strategist for a large multinational company, offers a simplified guide to some of the interlocking issues that led to the BEPS review.
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The new double tax treaty between Argentina and Spain has been in place for more than two months, having been signed in March (with retrospective effect to January 1 2013) after the unexpected termination of the old accord. Guillermo Teijeiro, of Teijeiro & Ballone Abogados, looks at why the old treaty was replaced, and analyses the new agreement in the context of Argentina’s wider treaty network.
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Opposition member of Parliament Catherine McKinnell is the Shadow Exchequer Secretary to the Treasury. If Labour win the next election, McKinnell could be the UK’s next minister for tax and her ideas on transparency and tackling avoidance in the UK and abroad may take global tax policy in a bold new direction. Salman Shaheen talks to McKinnell about where she believes the government is going wrong and what she would do differently.
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Antonio Carlos Marchetti Guzman and Ana Paula Schincariol Lui Barreto of Mattos Filho, Veiga Filho, Marrey Jr. e Quiroga Advogados look at the tax aspects of public subsidies in light of the introduction of Brazilian IFRS rules and the approach of the Brazilian administrative courts.
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Jeffrey Owens, the OECD’s former head of tax, and Mick Moore, of the University of Sussex, believe their 10 point action plan for the G8 summit this month could achieve fairer taxation of multinationals, improve tax transparency and help developing countries build up their tax capacity.
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While the requirement to furnish a tax residency certificate remains, some of the onerous amendments to the law have been done away with, adding a needed favourable chapter to India’s attempts to rationalise the law and practice of taxation of foreign companies in India, argues Avinash Narvekar of Ernst & Young
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Sumeet Khurana and S. Sriram of Lakshmikumaran & Sridharan look at marketing intangibles in light of the Maruti Suzuki case and contentious tax issues surrounding companies increasingly using international brands to market their products effectively.
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Rakesh Nangia of Nangia & Co look at value shifting in the context of the Shell India controversy.
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In the March edition of the magazine, Johann Muller, a member of the Danish Competent Authority for transfer pricing (TP), wrote about the issues that need to be addressed when looking at examples 1 and 2 to Annex C of the OECD Base Erosion and Profit Shifting (BEPS) report. Now, he proposes a simplified transfer pricing documentation process for vertically integrated multinational enterprises (MNEs). Both articles are written on a personal level and do not reflect the views of the Danish government.
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The financial services tax industry is becoming increasingly organised and coordinated in the Asia-Pacific region. One industry group, which stands out in the region, is the Capital Markets Tax Committee (CMTC) Asia. Sophie Ashley speaks to the newly elected chairman and vice-chairman of the group, Jesse Kavanagh, head of tax (Asia-Pacific except Japan) for Nomura Securities, and David Weisner, US tax counsel for Asia Pacific at Citigroup.
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Undeniably, the spotlight is increasingly falling on the tax affairs and tax payments of multinational corporations. While tax departments retain a duty to shareholders to minimise the tax liability, the debate around such tax strategies has evolved faster in the years since the global financial crisis than ever before. Matthew Gilleard analyses what this evolution means for today’s tax director.
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Jonathan Sheehan and Conor Hurley of Arthur Cox explore some of the tax measures that have been introduced in Ireland, including the opportunities that Irish vehicles can offer to international investors in Irish and non-Irish real estate and mortgage-backed loans.
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An ability to evolve and innovate in line with international regulatory developments and investor demand is key to the success of the Irish financial services industry. Martin Phelan and Niamh Keogh of William Fry Tax Advisors – Taxand highlight some recent tax changes and trends in their financial services practice.
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By 2025, four of the 10 largest economies in the world will be in Asia – China, India, Japan and Indonesia. Asia will account for approximately half of the world’s economic output. This is why the 21st Century is increasingly being recognised as the “Asian Century” – a period of sustained economic growth and prosperity, already taking place – and expected to continue throughout the region. Tim Gillis and Lachlan Wolfers of KPMG look at whether this growth will also see the rise of indirect taxes.
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All of Europe’s leading advisers were present at the Dorchester hotel in London on May 15 for the ninth annual European Tax Awards dinner.
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Juan Jose Terraza and Victor Bartels of Ernst & Young explain how two Spanish decisions should focus taxpayers’ attention on the design of limited risk arrangements