Covington & Burling has announced that Sam Maruca has returned to the firm as a partner. He will work in the firm’s Washington DC office and advise clients on federal income tax controversy and risk assessment, including transfer pricing. Maruca was most recently the director of transfer pricing operation for the large business and international division of the US Internal Revenue Service.
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
