Copying and distributing are prohibited without permission of the publisher

News and Analysis

  • The Cunningham column: China gets ready to lead tax world in 2016

    December 15, 2015

    China will be at the forefront of BEPS implementation in 2016, as president of the G20. Ralph Cunningham says it is a big opportunity for a non-OECD member to shape the international tax system.

  • The Brockman brief: BEPS implementation: A holiday wish

    December 15, 2015

    Drafters of the new base erosion and profit shifting (BEPS) actions and precision watchmakers share a common wish; that their immeasurable efforts devoted to refining and juxtaposing complex parts result in an instrument that is respected and trusted around the world.

  • BEPS Special

    December 15, 2015

    Matthew Gilleard introduces this exclusive, comprehensive insight into the work of the OECD in the area of countering tax base erosion and profit shifting (BEPS). Within these covers you will find out about the key messages delivered under each of the OECD’s 15 Actions, direct from the individuals responsible for putting each aspect of the project together.

  • Intercompany charges below EBIT: A double-edged sword

    December 15, 2015

    Luis Abrantes, tax director and head of transfer pricing at Carlsberg Group, draws on practical experiences to unpick the intricacies of intercompany charges.

  • India’s TP regime takes steps towards global best practices

    December 15, 2015

    Since the introduction of Indian transfer pricing regulations in April 2001, transfer pricing has become the most important international tax issue for businesses operating in the country, says Vatika Bhatnagar of Airtel India’s global transfer pricing team.

  • Mind your own business: The importance of knowing what we really do

    October 29, 2015

    Steven Ouwerkerk, global head of tax at APM Terminals, argues that to deal with the corporate challenges of operating in an increasingly borderless world, multinationals must learn to operate in a department-less manner, sharing experiences across functions and understanding issues from a variety of perspectives. He also brings a new meaning to the phrase ‘mind your own business’.

  • BEPS implementation: The role of a multilateral instrument

    October 27, 2015

    Jeffrey Owens, director of the Global Tax Policy Centre at the Vienna University of Economics and Business (WU) Institute for Austrian and International Tax Law (IAITL) and former OECD tax chief, and Nathalie Bravo, research associate at the IAITL, explore the role of a multilateral tax instrument in implementing BEPS Project measures, and analyse the treaty issues and technical challenges to be overcome.

  • The Brockman brief: Performance review: The OECD’s reputation

    September 29, 2015

    The curtain is drawing to a close on the final OECD BEPS recommendations, while the OECD actors and supporting staff anxiously await reaction from the audience. This month’s Brockman brief runs the rule over the OECD’s BEPS work to date and looks ahead to see how developments are likely to impact the organisation’s reputation as the ‘go-to’ body for international tax matters.

  • Americas Tax Awards 2015

    September 29, 2015

    Top honours at this year's Americas Tax Awards went to Deloitte, Baker & McKenzie and Skadden Arps Slate Meagher & Flom.

  • Tax and investment: UNCTAD’s contribution to the BEPS debate

    September 29, 2015

    The debate about international tax reform has received a valuable boost from the UN’s annual investment report, argues Jeffrey Owens of Vienna University of Economic and Business.

  • Americas Tax Awards 2015

    August 21, 2015

    The shortlists for the Americas Tax Awards 2015 have been released.

  • Issues the economist forgets? TP policy – a banking perspective

    August 21, 2015

    After spending 15 years in-house, Ben Henton last month joined BDO as a transfer pricing director. He returns to the UK from Asia after four years working at HSBC and DBS Bank in Hong Kong and Singapore. Here, he addresses operational risk challenges in transfer pricing (TP) from an in-house perspective, going beyond technical TP legislation and guidelines.

  • The Brockman brief: Illusory transparency: A symptom of BEPS complexity

    July 10, 2015

    The inception of the OECD’s base erosion and profit shifting (BEPS) action plans was accompanied by new demands for fiscal transparency, ignoring omnipresent thorns of complexity.

  • European Tax Awards 2015

    July 10, 2015

    The Grosvenor House Hotel on London’s Park Lane was the new venue for the 11th annual European Tax Awards dinner on May 21.

  • BEPS implementation in the US - Now comes the hard part

    July 10, 2015

    While the OECD has political backing and momentum behind it, the organisation has no binding authority to implement legislation, so the engagement of key jurisdictions including the US will be central to the project's ultimate success. Ryan Dudley, partner at Friedman, explains why the hard yards still lie ahead.

  • The Brockman brief: UK diverted profits tax: The extrapolation effect

    May 27, 2015

    The UK's diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are looking at similar moves; but exactly what tax doctrines will other countries adopt to achieve similar objectives?

  • BEPS: Improving data, economic analysis and measurement

    May 27, 2015

    It is stating the obvious to say that current international efforts to tackle base erosion and profit shifting (BEPS) have attracted a great deal of global attention. Since the OECD and G20 countries, working together on an equal footing, adopted a 15-point action plan to address BEPS in September 2013, the focus on this issue has steadily grown. David Bradbury, head of the tax policy and statistics division at the OECD Centre for Tax Policy and Administration, and the man overseeing this aspect of the project, provides exclusive insight into an action point that has not always received as much attention as other items in the Action Plan.

  • The Brockman brief: Timing symmetry is shattered: CbCR and TP documentation

    April 28, 2015

    May’s instalment of his column sees Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, look at the problems that may arise for taxpayers given the timing differences applicable for different documentation and reporting requirements, and what options are available for reconciling these.

  • Tax planners' task tougher than ever

    April 28, 2015

    Failing to plan is planning to fail. We are all familiar with the phrase. But practising what one preaches in this regard has never been more important for corporate taxpayers.

  • EU: Cross-border exchange of rulings - what's proposed?

    April 28, 2015

    Timothy Lyons QC and Kelly Stricklin-Coutinho of 39 Essex Chambers analyse recent transparency developments across Europe, focusing on the proposed requirement for EU member states to provide a quarterly report on all cross-border tax rulings and advance pricing arrangements.

  • DPT: Counterbalancing the UK's 'open for business' agenda?

    April 28, 2015

    The introduction of the UK's diverted profits tax (DPT) on April 1 2015 has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) it seemed intended to appease public anger at multinationals failing to pay their 'fair share' of tax. It has been roundly criticised for its breadth and complexity, for the speed with which it has been introduced, for the lack of public consultation and parliamentary scrutiny, and for pre-empting the multilateral response to tax avoidance of the G20/OECD BEPS Project. DLA Piper's Stephen Jones asks whether the DPT has created a cloud of uncertainty to cover the previous decade’s climate of reform favourable to global business.

  • The Brockman brief : TP risk determination: Transparency and mutuality

    March 25, 2015

    This month, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, runs the rule over issues of transfer pricing risk determination, focusing on transparency and the benefits of increased levels of authority reciprocity.

  • Pascale Colin: Defining challenges for today's group tax manager

    March 25, 2015

    Matthew Gilleard talks with Pascale Colin, group tax manager at EFG Bank, about the role of the tax director, her journey in getting there, and operating successfully in a rapidly-evolving Swiss, European and global tax environment

  • Practical considerations for Chinese withholding tax on cross-border service transactions

    March 25, 2015

    The potential Chinese tax implications of the provision of cross-border services into China are as numerous as they are confusing. Scott Heidecke and Flora Luo of Nexia International member firm Nexia TS (Shanghai) discuss some of the practical considerations.

  • The Brockman brief: Interest: Double taxation equality is fading

    February 24, 2015

    In the first of his regular monthly updates, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, looks at why countries are enacting unilateral legislation to limit interest deductibility, the shift in focus from eliminating double taxation to eliminating non-taxation, and why, as a result, double taxation via interest limitations is here to stay.

  • Keeping track of a shifting transfer pricing landscape

    February 24, 2015

    Maik Thomas Heggmair of WTS discusses recent transfer pricing changes in Germany, including the adoption of the authorised OECD approach (AOA) into German legislation and incoming reporting changes and provides practical views on recent audit experiences.

  • BEPS – Preventing treaty abuse: A practical perspective

    January 27, 2015

    Keith Brockman, global tax director at Mars and author of the International Tax Best Practices blog, analyses BEPS Action 6 on preventing treaty abuse, calling for more balance in seeking to avoid double taxation and double non-taxation, and more guidance on the interplay between domestic law and treaty interaction.

  • Moving goalposts mean taxpayers must stay on toes

    January 27, 2015

    Joe Stanley-Smith analyses how new attitudes and initiatives from tax authorities in key jurisdictions will influence the national and international tax dispute landscape in 2015.

International Tax Review Profile

RT @CBItweets: UK needs a Budget that enables the country to grow its way out of austerity. Here are 5 business priorities https://t.co/CAw

Oct 19 2017 09:19 ·  reply ·  retweet ·  favourite
International Tax Review Profile

This year's World Tax directory is now online. How does your firm stack up? https://t.co/CtRbW1Ub5j

Oct 19 2017 09:13 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @AuroChardon: Let's honour the #memory of a brave #journalist and woman ➡️ vigil tomorrow, 18 Oct, 6pm, in front of Residence Palace #Da…

Oct 18 2017 04:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Big Soda scores victory as Chicago-area tax repealed - could this be the beginning of the end of the sugar tax trend?https://t.co/PNuafWHy9K

Oct 12 2017 04:03 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Ebay and Netflix pay total UK tax of less than £1.9m - How long until HMRC investigate their TP practices? https://t.co/VPPsT3aGMZ via @FT

Oct 12 2017 03:59 ·  reply ·  retweet ·  favourite
International Correspondents