While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, and rejects protection for indirect transfers and tightening conditions for Mauritius‑based investors claiming DTAA relief
The expansion introduces ‘business-level digital capabilities’ for tax professionals, the US tax agency said
Editorial Board
ITR is excited to unveil its inaugural Editorial Board, comprised of a select panel of tax industry experts
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
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Sponsored by Deloitte Transfer Pricing GlobalTransfer pricing (TP) litigation surrounding the energy and resources (E&R) sector has increased drastically over the past two years. While determining the owner of the commodity price risk has drawn increased attention, Deloitte’s Mark Barker and Aengus Barry discuss how tax authorities predominantly employ the comparable uncontrolled price (CUP) method in any TP dispute. -
Sponsored by Deloitte Transfer Pricing GlobalOffshore marketing hubs are becoming increasingly commonplace for Australian resource firms in Asia. Deloitte’s John Bland and Milla Ivanova discuss what factors may trigger increased regulatory scrutiny for a multinational under the Australian Taxation Office’s (ATO) risk ratings.
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Sponsored by Deloitte Transfer Pricing GlobalVolatile oil markets in 2018 presented significant challenges to Canadian exporters, but a shortage in natural gas production globally presented a complimentary opportunity. Deloitte’s Andreas Ottosson and Markus Navikenas discuss the transfer pricing implications.
Direct Tax
Zion Adeoye, a tax specialist, had been suspended from the African law firm since October over misconduct allegations
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
Transfer Pricing
Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights 'significant concerns'
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
The APA resolution signals opportunities for multinationals and will pacify investor concerns, local experts told ITR
Indirect Tax
Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention
The US president’s threats expose how one superpower can subjugate other countries using tariffs as an economic weapon
Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
Jurisdictions
Features and Special Focus
