Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood
Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning
‘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
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Sponsored by KPMG GlobalAfter the initial hype, Lachlan Wolfers and Garth Roark of KPMG consider whether generative AI is seen as a fear, foe, or friend in the tax world, and explain how it could help practitioners -
Sponsored by Mason RakOverall, 2023 saw the world of tax seek to solidify common standards via a significant legislative overhaul. Oleg Rak, managing partner of specialist tax recruitment firm Mason Rak, analyses current trends from the year, and what they mean for tax leaders looking to gain an advantage in a competitive market
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Sponsored by Vertex IncAgainst the backdrop of a domino effect in the introduction of mandatory e-invoicing among EU member states, Gunjan Tripathi of Vertex says businesses should future-proof themselves by proactively addressing the transition
Direct Tax
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 hire of Doug Wick expands Baker McKenzie’s state and local tax practice and adds to the firm’s growing ex-IRS expertise
One year after Nuwaru joined the WTS network, leaders James Jobson and Matthew Missaghi reflect on the firm’s mission to offer mid-tier pricing but deliver top-tier results
The president’s tariff regime has already caused misery for taxpayers. Losing at the Supreme Court would mean it was all for nothing
Transfer Pricing
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
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
Indirect Tax
Canadian and Indian dual VAT models have been a source of inspiration for the Brazilian model, but the latter has unique and innovative features, the OECD paper claimed
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
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
