ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
The boutique Australian firm’s TP award recognition proves that world-class advisory services aren’t limited to the ‘big four’, the firm’s founder tells ITR
‘Mutual accountability’ required to fix German client cost grumbles
As ITR’s client data reveals discontent with German advisers’ cost management, Grant Thornton’s TP head insists it’s a two-way street
Editorial Board
ITR is excited to unveil its inaugural Editorial Board, comprised of a select panel of tax industry experts
Awards
The boutique Australian firm’s TP award recognition proves that world-class advisory services aren’t limited to the ‘big four’, the firm’s founder tells ITR
Join ITR's Head of Research, John Harrison, for an overview of key dates, new developments, best practices, and more for next year’s research cycle
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
-
Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados discusses the new regulation concerning the declaration of tax benefits and the additional – and unnecessary – difficulties for taxpayers -
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
-
Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Pietro Bricchetto of Gatti Pavesi Bianchi Ludovici examine the Italian tax authorities’ interpretative position concerning the VAT regime applicable to dispute financing services provided within the framework of third-party litigation funding agreements
Direct Tax
The president’s tariff regime has already caused misery for taxpayers. Losing at the Supreme Court would mean it was all for nothing
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
AI will mean fewer entry-level roles in tax but also the emergence of new jobs, according to tax expert Isabella Barreto
Transfer Pricing
Identifying who will bear the costs and concerns around confidentiality are issues yet to be resolved, advisers say
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
APAs should provide a pragmatic means to agree to an arm's-length outcome for an Australian entity and for the ATO, the tax authority said
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
Indirect Tax
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
Increasingly complex reporting requirements contributed towards the firm’s growth in tax, it said
The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
Featured Global Tax 50 profiles
ITR presents the 50 individuals who exerted the most influence on tax during 2024 – for better or worse – with world leaders, in-house award winners, activists and others making the cut
Jurisdictions
Features and Special Focus
