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
            
        
  
    
    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
    
    
      
        
    
      
    
    
    
  Overall revenues and average profit per partner also increased in the UK, the ‘big four’ firm revealed 
    
    
      
        
    
      
    
    
    
  ‘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
      
    
    
      
          Awards
        
      
    
    
      
        
      
    
    
      
    
    
    
      
    
    
      The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
    
    
      
        
    
      
    
    
    
  Corporate counsel should combine deep technical knowledge with strategic dynamism, says Agarwal, winner of ITR’s EMEA In-house Indirect Tax Leader of the Year award 
    
    
    
      
        
    
      
    
    
  
          Awards
        
      
    
    
      
        
      
    
    
      
    
    
    
      
    
    
      The ‘big four’ firm scooped over 60 honours at a lively ceremony held at The Londoner hotel, including both EMEA and APAC Tax Advisory Firm of the Year
    
    
      
        
    
      
    
    
    
  
          Awards
        
      
    
    
      
        
      
    
    
      
    
    
    
      
    
    
      ITR is delighted to reveal the first shortlisted nominees for the Middle East Tax Awards
    
    
      
        
    
      
    
    
    
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            Sponsored by Lakshmikumaran & SridharanS Vasudevan and Prachi Bhardwaj of Lakshmikumaran & Sridharan explain how India’s tax authorities face legal pushback over the Multilateral Instrument’s enforceability, with most favoured nation rulings now affecting its implementation
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            Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosSolange Dias Nóbrega of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines the Portuguese government’s plan to phase out indirect SIFIDE and questions whether ending this R&D tax benefit could hinder innovation and entrepreneurship
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            Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on the rising concerns about the tax reform transition phase, especially concerning how the old taxes will be calculated during their coexistence with the new system
        Direct Tax
      
    
    
      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
    
    
      
        
    
      
    
    
    
  If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
    
    
      
        
    
      
    
    
    
  If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
    
    
      
        
    
      
    
    
    
  As World Tax unveils its much-anticipated rankings for 2026, we focus on EMEA’s top performers in the first of three regional analyses  
    
    
      
        
    
      
    
    
    
  
        Transfer Pricing
      
    
    
      Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
    
    
      
        
    
      
    
    
    
  TP is a growing priority for West and Central African tax authorities, writes Winnie Maliko, but enforcement remains inconsistent, and data limitations persist
    
    
      
        
    
      
    
    
    
  Increasingly, clients are looking for different advisers to the established players, Ryan’s president for European and Asia Pacific operations tells ITR
    
    
      
        
    
      
    
    
    
  The tariffs are disrupting global supply chains and creating a lot of uncertainty, tax expert Miguel Medeiros told ITR’s European Transfer Pricing Forum
    
    
      
        
    
      
    
    
    
  
        Indirect Tax
      
    
    
      In the age of borderless commerce, money flows faster than regulation. While digital platforms cross oceans in milliseconds, tax authorities often lag. Indonesia has decided it can wait no longer
    
    
      
        
    
      
    
    
    
  Prudential had challenged HMRC over VAT group relief; in other news, Donald Trump unveiled timber and wood tariffs, and the European Commission published a ViDA implementation strategy
    
    
      
        
    
      
    
    
    
  Section 899’s exclusion from the One Big Beautiful Bill does not mean it has been nipped in the bud, Aruna Kalyanam also tells ITR
    
    
      
        
    
      
    
    
    
  US President Donald Trump’s tariffs may get thrown out by courts in the future and taxpayers should already be planning for that possibility, BDO’s Dustin Stamper tells ITR
    
    
      
        
    
      
    
    
    
  
        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
      
    
    
       
    
     
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
