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 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
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
‘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 DLA Piper AustraliaJock McCormack of DLA Piper Australia summarises Australia’s latest proposed double tax agreement as the country’s treaty reforms gather pace, and potential changes to the non-resident capital gains tax withholding rate and threshold -
Sponsored by DeloitteDeloitte’s Tax Transformation Trends survey has highlighted key considerations for organisations shaping their talent strategies. Mary Fabean, Gina Salama, and Michelle Tariq of Deloitte suggest five ways to adapt to a rapidly changing tax environment
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Sponsored by GNV ConsultingThis month’s summary, by Ahdianto Ah and Reza Farhan of GNV Consulting, also explains a regulation providing for an import duty exemption on certain seeds and seedlings, and new supervisory powers for customs officials
Direct Tax
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The president’s tariff regime has already caused misery for taxpayers. Losing at the Supreme Court would mean it was all for nothing
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
Transfer Pricing
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
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
Indirect Tax
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
The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
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
