Copying and distributing are prohibited without permission of the publisher

News In Brief

News and Analysis

  • The Global Tax 50 2014

    December 16, 2014

    Now in its fourth year, International Tax Review's Global Tax 50 provides a rundown of the who’s who of the tax world. One way or another, the individuals and organisations on this list have had an impact or influence on taxation that will be felt beyond, or outside of, the 12 month period covered by this list.

  • China: You can download the latest edition of our guide now

    December 08, 2014

    The 4th edition of China - Looking Ahead is available as a downloadable pdf. It features articles on how China regards the BEPS project, the progress of the VAT reforms and what China expects from multinationals on transfer pricing.

  • International Tax Review at 25: What has changed in a quarter of a century

    October 30, 2014

    Tax has changed dramatically since the first issue of International Tax Review came out in November 1989. Using a selection of articles – one from each year – Ralph Cunningham and Matthew Gilleard assess how many of those changes have been reflected in the publication over the past 25 years.

  • France asserts PE in commissionaire structures again

    October 30, 2014

    Eric Meier and Ariane Calloud, of Baker & McKenzie, analyse a recent case about potential permanent establishment of a French entity operating under a commissionaire arrangement with its Swiss principal.

  • The changing face of tax havens

    October 01, 2014

    The phrase tax haven has long conjured images of letterbox companies metres away from the golden sands and deep blue seas of Bermuda’s beaches. But is that moniker appropriate or is the stereotype shifting as European jurisdictions such as Denmark and the UK’s City of London are being stamped with the tax haven label following recent reform measures? Matthew Gilleard looks at tax competition in specific country contexts to see whether the face of tax havens is changing.

  • Latin America Focus 2014 now available

    September 30, 2014

    With reforms underway in a number of countries in the region, and international initiatives to keep track of, leading advisers update you on the latest developments from across Latin America.

  • Transfer Pricing Industry Guide 2014 now available

    September 24, 2014

    Deloitte's industry experts examine the factors driving the pricing of intercompany transactions in the technology, oil and gas, life sciences, media and entertainment, consumer products, manufacturing and financial services sectors.

  • Holding Companies Focus 2014 now available

    September 16, 2014

    Leading advisers from Eurofast in Cyprus, Grant Thornton in Ireland, KPMG in Malta and KPMG in Switzerland explain what each of their jurisdictions is doing to strengthen their appeal as holding company locations.

  • World Tax Authority: Taking harmonisation to the next level

    August 29, 2014

    Recent attempts at tax harmonisation have struggled to take off. In Europe enhanced cooperation measures are being invoked because of the inability to find consensus. But what fate awaits the notion of a World Tax Authority (WTA)? Would it take tax harmonisation to the next level or, like the Europe-wide language of Esperanto, is this attempt at harmonisation doomed to fail? Matthew Gilleard analyses what has motivated discussion of such a concept and looks at the barriers to implementation.

  • Going the extra mile - when finance and IT suddenly awoke

    August 29, 2014

    In the July/August issue, Frank Schoeneborn, head of group operational transfer pricing in the finance and accounting division at Merck Group, took a retrapolative look at the country-by-country reporting standard five years into its implementation. In part two, he looks at how different functions within a multinational company are interacting with the tax team to manage reporting obligations.

  • Alternative dispute resolution: Alleviating burdens all round

    August 29, 2014

    The number of tax disputes is increasing rapidly around the world. The trend is encouraging governments to turn to alternative dispute resolution (ADR) in a bid to reduce backlogs in the courts. While ADR is well established in some jurisdictions, in others it is just getting going. Aaran Fronda looks at how ADR has become an increasingly viable solution for resolving tax disputes.

  • The IMF and international tax

    August 29, 2014

    David Spencer, of the Law Offices of David Spencer in New York, analyses the recent work of the International Monetary Fund (IMF) and assesses its growing influence in the area of international taxation.

  • BEPS and CbCR: A retrapolation five years on

    July 01, 2014

    One of the most contentious issues being considered as part of the OECD’s base erosion and profit shifting (BEPS) project is the notion of country-by-country reporting (CbCR) of multinational companies' tax information. Frank Schoeneborn, head of group operational transfer pricing in the finance and accounting division at Merck Group in Germany, steps forward in time to take a hypothetical look at the reporting standard five years after implementation.

  • European Tax Awards 2014

    July 01, 2014

    The winners of the European Tax Awards 2014 were announced at a dinner in London on May 21.

  • What chief financial officers need from their tax directors

    July 01, 2014

    Jean-Louis Huchant, a former chief financial officer in France, explains what information and support a CFO requires from a tax director to ensure that tax considerations are taken into account, though do not dominate, business decisions.

  • Transfer pricing risk management: A case for APAs

    July 01, 2014

    Victor Adegite of KPMG Nigeria looks at the advance pricing agreement (APA) option as a tool taxpayers can use as part of their transfer pricing risk management, highlighting the benefits of different types of APA and looking at how APA programmes operate in other jurisdictions.

  • Transfer Pricing Focus 2014 now available

    June 23, 2014

    BEPS has taken centre stage in global transfer pricing over the past year and recent debates have focused on country-by-country reporting, among other things. The issue of profit shifting has consequently been a strong theme in this year's transfer pricing supplement, but readers can also get the latest updates on supply chain management and insights into regulation changes from a jurisdictional perspective.

  • Americas Tax Awards 2014 - Make sure your company or firm is in the running

    June 20, 2014

    The research process for International Tax Review’s Americas Tax Awards 2014 has begun. This is your chance to participate.

  • Financial Services Focus 2014 now available

    June 17, 2014

    Ahead of the launch of International Tax Review's Financial Services Tax website, the annual publication on Capital Markets tax developments has been repositioned to offer a greater breadth of topical coverage for financial services taxpayers and their advisers.

  • Base Firma and Quantera Global form strategic alliance

    June 16, 2014

  • Apple, Fiat and Starbucks rulings attract state aid investigations

    June 13, 2014

    The European Commission has opened formal state aid investigations into three tax rulings agreed between Apple, Fiat and Starbucks with the Irish, Luxembourg and Netherlands tax authorities, respectively.

  • Ryan adds transfer pricing with purchase of Altus International

    June 04, 2014

  • Inversions: The trend turning transactional tax planning upside down

    May 27, 2014

    Mention the word ‘inversion’ or ‘inverted’ and the first things likely to come to mind for most people are inverted commas – the most supercilious of the English language’s punctuation marks, looking down on regular commas from their lofty perch with scorn. Possibly La Pyramide Inversée at Le Louvre, too. But mention those words today and a tax efficient restructuring mechanism may also feature. Matthew Gilleard explores the inverted reality of this transactional trend.

  • Russian de-offshoring may affect international businesses

    May 27, 2014

    Taxation of cross-border structures and new exchange of information measures are two reasons why Russia’s new de-offshoring policy will have an impact on foreign as well as domestic groups, explain Estella Dzhantukhanova, Elena Solovyova, Alexander Krylov and Kateryna Grynova of Deloitte, Russia.

  • Asia tax directors do battle with lengthy in-tray

    May 27, 2014

    The two-day Asia Tax Forum covered a range of issues and countries, not just BEPS, including dispute resolution and anti-avoidance, transfer pricing and China’s VAT reforms, reports Ralph Cunningham.

  • Why do publicly-traded companies like Ireland?

    May 27, 2014

    Publicly-traded companies seemingly have an affinity towards Ireland. Is it purely a pursuit of the Emerald Isle’s temperate climate that attracts them? Conor Hurley and Ailish Finnerty of Arthur Cox analyse the factors influencing taxpayer decisions to locate in Ireland, debunking the idea that such decisions are solely tax-driven.

  • Avoiding the snares of international tax structures

    May 27, 2014

    International business expansions can substantially increase the bottom line, but this outcome is largely dependent on establishing an efficient structure that helps to ensure financial success. Lee Sheehan, head of tax at Radius, looks at the importance of a clear strategy when setting up tax structures for specific business locations, and points out some of the landmines to avoid along the way.

  • World Tax 2016 and World Transfer Pricing 2016: Research opens in May 2015

    May 21, 2014

    The research will start for the 2016 editions of World Tax and World Transfer Pricing in May 2015. Please watch this website closely for further information.

  • International updates - May 2014

    May 01, 2014

    The latest international updates from our correspondents around the world.

  • According to plan? The world of tax planning is changing, but not as fast as everyone would like

    April 30, 2014

    The world of tax planning is like one big global tug o’ war being played between multinational companies and their advisers, tax authorities, supranational bodies and non-governmental organisations. Everyone has an interest in changing the international tax system. But with everyone pulling in different directions, the pace of change is frustrating for most.

  • The journey into the future for Swiss principal companies?

    April 30, 2014

    Urs Landolf, Martina Walt and Christoph Pauli of PwC explain the impact new interpretations of principal company taxation by the Swiss federal tax authorities will have on all existing companies benefiting from circular no 8.

  • Managing TP risks in Nigeria: The importance of proactivity

    April 30, 2014

    Nigerian transfer pricing rules are still in their relative infancy, but taxpayers must take adequate steps to prepare now if they are to effectively identify risk areas and plan with both the company policy and the prospect of audit in mind. Victor Adegite of KPMG Nigeria provides an overview and looks at what lessons can be learnt from experiences around the world.

  • Special features - May 2014

    April 30, 2014

    Read this month's special features on Turkey and tax technology.

  • International updates - April 2014

    March 31, 2014

    The latest tax updates from around the world.

  • Teamwork central to Telefônica’s tax compliance in Brazil

    March 28, 2014

    Vasco Gruber Franco is head of tax for the Telefônica group in Brazil. He previously worked on the advisory side at Arthur Andersen, and has held other in-house roles at DuPont and Philip Morris. Here, he talks to Matthew Gilleard about heading up a tax department in Brazil.

  • Operational TP: When tax function meets finance function

    March 28, 2014

    Frank Schoeneborn, head of global operational transfer pricing in the finance and accounting division at Merck Group with headquarters in Germany, looks at the practical problems in the implementation of operational transfer prices, illustrating the new tax risks stemming from these problems and showing how holistic management can be the solution.

  • India: Profit attribution to permanent establishments

    March 28, 2014

    Sanjay Sanghvi and Ashish Mehta of Khaitan & Co. analyse recent tax rulings dealing with the attribution of profits to permanent establishments, looking at what multinationals can do to avoid becoming embroiled in similar disputes in the future.

  • Implications for maquiladoras of the 2014 Mexican tax reform

    March 28, 2014

    Ricardo León-Santacruz and Fernando Lujan of Sánchez-DeVanny Eseverri explain how the Mexican 2014 tax reform limits tax incentives and imposes new administrative burdens on the maquiladora sector, which is made up of wholly owned companies that process or assemble imported materials and parts into finished products for sale to the country of origin or other parts of the world.

  • Asia Transfer Pricing Focus 2014 now available

    March 14, 2014

    Leading transfer pricing advisers from KPMG in Australia, China, Hong Kong, India, Indonesia, Japan, Korea, Malaysia, New Zealand, the Philippines, Singapore, Taiwan, Thailand and Vietnam bring you insights and advice from across the region.

  • Swiss Focus 2014 now available

    March 07, 2014

    If one country has been a trailblazer in using the tax system to attract investment, it is Switzerland. But against a backdrop of international reforms and pan-European harmonisation, the scope for challenge of national regimes is increasing. Compliance initiatives such as the US FATCA, and the way it has been imposed on financial institutions and tax authorities around the world, highlight that outliers will no longer be tolerated. With this in mind, the 3rd edition of ITR's Swiss Focus brings you the latest domestic developments and analysis of how multilateral reforms are impacting taxpayers in Switzerland.

  • Special features - March 2014

    February 26, 2014

    Read this month's special feature on tax audits.

  • OECD seeks increased tax transparency from multinationals

    February 06, 2014

    The OECD has released a discussion draft outlining its proposals on information that multinationals may be required to disclose to tax authorities about their global operations.

International Tax Review Profile

So, ITR readers. Will the US tax reform bill make it to Trump's desk by Christmas?

Dec 18 2017 11:17 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EU_Competition: State aid: @EU_Commission opens in-depth investigation into the Netherlands' tax treatment of Inter IKEA https://t.co/b

Dec 18 2017 11:12 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @EU_Commission: We have opened an in-depth investigation into the Netherlands' tax treatment of Inter IKEA, one of two groups operating…

Dec 18 2017 11:12 ·  reply ·  retweet ·  favourite
International Tax Review Profile

@coaol thoroughly deserved

Dec 18 2017 10:54 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Gangsta Tax Made Me Do It #GlobalTax50 #taxtwitter https://t.co/qazdqBOuZ0

Dec 18 2017 09:43 ·  reply ·  retweet ·  favourite
International Correspondents