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  • The Brockman brief: CbCR examined: Is this a TEST (transparent effort to shift taxes)?

    Country-by-country reporting (CbCR) has been heralded as the solution to the perceived problem that existing accounts for multinationals do not, and cannot, provide a true and fair view of business. This month’s Brockman brief takes taxpayers through the proposed model CbCR template.

  • Americas Tax Awards 2015

    The shortlists for the Americas Tax Awards 2015 have been released.

  • Disclosure of intercompany agreements under BEPS

    Much time and attention has been devoted to planning for a post-BEPS world, from analysing systems that may need to be adopted to looking at how taxpayer-tax authority relationships are likely to change. But less has been said about the impact of BEPS deliverables on commercial contract documentation and the extent to which such contracts will be scrutinised. Jen Winterhalder, a solicitor in PwC Legal and Latika Sharma, a partner and head of PwC Legal’s intellectual property and commercial contracts team, focus on the importance of matching contract terms to commercial substance, both now and for the future.

  • A coordinated approach to combat tax fraud and evasion

    Lyudmila Petkova, director of the Bulgarian Ministry of Finance’s Tax Policy Directorate, outlines the moves being made to counter tax fraud and tax evasion in Bulgaria at national level, as well as how this fits into wider regional and global efforts to tackle abuse.

  • Winds of change: Energy taxation evolving as oil price slips further

    A turbulent year for the energy sector has seen oil prices decreasing by more than half from June 2014 to the beginning of 2015 and brent crude oil dipping below $50 a barrel for the first time since May 2009. This volatility has caused longer term, widespread repercussions across the industry. Jimmie van der Zwaan from Taxand Netherlands looks at some of the consequences impacting the sector, including an increase in M&A activity, tax concessions instigated by governments and major oil companies announcing ravaged profits - and this is before considering the gathering momentum of the OECD's initiatives to tackle base erosion and profit shifting (BEPS) in international tax planning.

  • Special features - September 2015

    Read this month's special features for GCC, Intangibles and Mexico

  • Tearing up the VAT Directive: Reduced rates reform

    With the European VAT Directive set for a drastic rewrite, Joe Stanley-Smith gets the inside line from the man who oversaw this year’s implementation of the place of supply rules, and takes in advisers’ views on how stakeholders will be affected.

  • The new Italian Patent Box regime

    As governments around the world assess the best way to attract – and tax – R&D and intellectual property investment, Giulia Cipollini and Bianca Macrina of Withers in Milan look at the incentives taxpayers can avail in Italy, tracking the nuances of the Italian Patent Box regime from introduction to operation.

  • Issues the economist forgets? TP policy – a banking perspective

    After spending 15 years in-house, Ben Henton last month joined BDO as a transfer pricing director. He returns to the UK from Asia after four years working at HSBC and DBS Bank in Hong Kong and Singapore. Here, he addresses operational risk challenges in transfer pricing (TP) from an in-house perspective, going beyond technical TP legislation and guidelines.

  • A tax system for sustainable growth

    In this exclusive op-ed piece for International Tax Review, Chris Lenon, former head of tax for Rio Tinto and an expert witness to the Independent Commission for the Reform of International Corporate Taxation (ICRICT), argues that a focus on incentives and ultra low or no tax jurisdictions should be policy makers’ priority, rather than ideas included in the commission’s report, such as allocation.

  • How long will a ‘voluntary’ code of practice remain voluntary?

    Charles Yorke and David Stainer, of Allen & Overy, review the latest UK Government proposals on improving compliance by large corporate taxpayers, including a ‘voluntary’ code of practice likely to give rise to fears of ‘mission creep’.

  • Anson: Practical implications for investment managers and funds

    Dan Roman and Aron Joy of KPMG look back on Anson, tracking the background to the case before focusing on the types of structure that could be affected by the decision and how this impact may manifest itself in practice.

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International Correspondents

International Correspondents