As part of its continuing efforts to improve international operations, the US Internal Revenue Service (IRS) recently announced the reorganisation of its advance pricing agreement (APA) and mutual agreement procedure (MAP) programmes into a combined advance pricing and mutual agreement (APMA) programme. Kerwin Chung and Todd Wolosoff of Deloitte explain what the reorganisation, and its potential impact on taxpayers seeking APAs, will mean.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
The boutique Australian firm’s TP award recognition proves that world-class advisory services aren’t limited to the ‘big four’, the firm’s founder tells ITR
Canadian and Indian dual VAT models have been a source of inspiration for the Brazilian model, but the latter has unique and innovative features, the OECD paper claimed
More sophisticated use of technology, heightened TP scrutiny and stricter filing requirements are making South African Revenue Service audits a formidable challenge
One year after Nuwaru joined the WTS network, leaders James Jobson and Matthew Missaghi reflect on the firm’s mission to offer mid-tier pricing but deliver top-tier results
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires