In light of the US Tax Court’s decision in Amazon v. Commissioner of Internal Revenue, many important predictions have been made about the impact this case will have on future transfer pricing litigation. However, it is important to look at the valuable lessons that should be learned by practitioners, corporations, attorneys, and tax authorities when documenting intercompany transactions, specifically intangibles. John Wiora, director of operations at ktMINE, investigates.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Effective audit management requires more than documentation; it’s the way taxpayers engage that can shape audit direction, manage procedural ambiguity, and preserve options for appeal or litigation
American advisers are falling short of client expectations when it comes to providing value-added services, but remaining tight-lipped won’t make the problem go away
Australia's approach to tax policy has undergone significant shifts in recent years, reflecting global trends and unique domestic considerations. These developments merit close attention from tax professionals
Following a $28 million funding round, Aibidia wants to ‘double down’ on the US market via partnerships with the ‘big four’, the Finnish TP tech provider’s CEO tells ITR