Under long-anticipated regulations published by the US Internal Revenue Service (IRS), cost sharing arrangements (CSAs) remain an effective tool that multinational taxpayers can use to efficiently develop and manage ownership of valuable intangible property among subsidiaries. But valuations of pre-existing, platform intangibles contributed to CSAs will be scrutinised by the IRS going forward
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Corporate counsel should combine deep technical knowledge with strategic dynamism, says Agarwal, winner of ITR’s EMEA In-house Indirect Tax Leader of the Year award
Ryan hopes the buyout will help it expand into Asia and the Middle East; in other news, three German finance ministers have called for a suspension of pillar two
Prudential had challenged HMRC over VAT group relief; in other news, Donald Trump unveiled timber and wood tariffs, and the European Commission published a ViDA implementation strategy