Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes
While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Introducing ITR’s new monthly podcast - Taxing Times
Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution
What Corporates Want: DEI is fading with or without Trump
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
Featured Global Tax 50 profiles
ITR presents the 50 most influential people in tax from 2025, including world leaders, in-house award winners and activists
Awards
Awards
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
Awards
View the official winners of the 2025 Social Impact EMEA 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
-
Sponsored by Deloitte MexicoDeloitte’s Simon Somohano and Eduardo Campos explain the Mexican tax authority’s latest non-binding transfer pricing criteria, which some have labelled heavy handed. -
Sponsored by Deloitte South AmericaSouth America is in the throes of implementing the OECD BEPS project with new regulations emerging from every corner of the region, write Deloitte’s Latin America Countries Organisation practitioners. The developments clearly signal a tougher stance by authorities on transfer pricing and indicate that advance pricing agreements may be a key tool of the future.
-
Sponsored by Dhruva AdvisorsThe subject of transfer pricing (TP) has gained a great deal of momentum globally over the past couple of years. Most of the OECD and G20 countries have implemented TP legislation even before the BEPS initiative and have issued further regulations considering the recommendations of the BEPS Action Plan reports.
Direct Tax
As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management
While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’
From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal
Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’
Transfer Pricing
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
Indirect Tax
IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing
The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed
A 120-plus-day delay to refunds would cost taxpayers almost $3bn in additional interest, the Cato Institute warned; plus indirect tax updates from February
Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty
Jurisdictions
Features and Special Focus
