Panelists at the April 2011 International Bar Association, International Fiscal Association 11th Annual Tax Planning Strategies, US and Europe conference in Paris discussed a key aspect of the current OECD project on the transfer pricing of intangibles, namely the specification and resolution of the intangible issues that can arise in a business restructuring.
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The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
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