New reforms represent the most seismic shift in Canadian TP legislation since its enactment and a clear inflection point for MNEs, ITR has heard
Spain did not transpose EU VAT rules for SMEs or works of art; in other news, an increased VAT threshold came into force in South Africa
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
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: clients laud Indian advisers' local knowledge
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
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 DLA Piper NetherlandsRachit Agarwal and Jian-Cheng Ku of DLA Piper discuss the transfer pricing (TP) aspects of a business restructuring within a multinational enterprise (MNE) group, through reference to a recent high-stakes Dutch court case. The case highlights the importance of TP documentation as evidence in tax litigation and in conducting an appropriate TP valuation. -
Sponsored by PwC ChileWithout much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related for transfer pricing purposes, write Roberto Carlos Rivas and Gregorio Martínez of PwC.
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Sponsored by MathesonThe Irish Revenue Commissioners (Revenue) were successful in arguing before the Appeal Commissioners that no general trading deduction should be available for excess foreign tax incurred on royalties where an Irish tax credit was claimed for part of the foreign tax withheld. The decision is being appealed to the High Court.
Direct Tax
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series
But partners at the firm admit that jumping ship to the US would not be as easy as some believe
Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created
Transfer Pricing
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management
Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
Indirect Tax
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
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
Jurisdictions
Features and Special Focus
