Taxpayers have made six proposals to the Canadian government to maintain the international competitiveness of the economy, including the elimination of withholding tax on intercompany dividends in the Canada-US tax treaty, the introduction of a participation exemption for foreign dividends and the establishment of a system that would allow for loss transfer or group loss relief
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The software space was previously more fragmented, but that model is becoming more difficult to sustain as tax administration becomes increasingly digitised
While some may argue that heads should roll following KPMG Australia’s audit leak scandal, client and revenue data emphasises that tax team stability is paramount
A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation