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Transfer Pricing
features sponsored features special focus local insights
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New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer
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AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems
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Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria
Sponsored Features
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Sponsored by Lorenzo PiccardiTaxing multinationals in the digital services sector has remained a complex international challenge for local governments limited in their jurisdictional capabilities. Tremonti’s Lorenzo Piccardi, Simone Zucchetti and Armando Tardini discuss how Italy is facing these challenges through regulatory developments surrounding permanent establishments and web taxes.
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Sponsored by EY LondonTransatlantic deals between the US and Europe have fallen since the end of 2017, although activity levels in the US domestic market have increased. Can this be attributed to US tax reform? And what has US tax reform meant for transatlantic M&A more generally? EY’s James Hume and Joe Toce consider these questions and the broader impact on due diligence, financing and post-acquisition integration.
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Sponsored by Fenwick & WestWhile US tax reform may not have affected merger and acquisition (M&A) activity explicitly, a change in laws surrounding controlled foreign corporations (CFCs) will see a number of new tax considerations emerge for US buyers and sellers. Fenwick & West’s Adam Halpern and William Skinner discuss how these changes might influence cross-border M&A activity.
Special Focus
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Sponsored by DeloitteVanesa Lanciotti of Deloitte Chile explores how recent reforms – including new advance pricing agreement rules, enhanced audit priorities, and disclosure requirements – are reshaping transfer pricing practice and compliance for multinationals operating in Chile
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Sponsored by DeloitteSenior Deloitte tax practitioners examine Mexico’s evolving approach to the OECD’s amount B and summarise the transfer pricing landscape in Guatemala, Panama, Honduras, and Costa Rica
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Sponsored by DeloitteSenior Deloitte tax practitioners report that transfer pricing audits are homing in on intercompany services in Argentina, Uruguay, Colombia, Peru, Ecuador, and Venezuela, and emphasise the need for early taxpayer preparation
Local Insights
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Sponsored by MDDPPoland: Clarified beneficial ownership rules and introduction of overseas investment fund exemptionsJustyna Bauta-Szostak and Gniewomir Parzyjagła of MDDP say the new guidance on withholding tax is a step forward for businesses operating across borders and overseas funds investing in Poland
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Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosRaquel Maurício of Morais Leitão, Galvão Teles, Soares da Silva & Associados examines recent Portuguese VAT changes aimed at urban rehabilitation and why legal uncertainties risk undermining the housing goals they aim to support
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Sponsored by KPMG SwedenMarie Hedin and Jennifer van der Gronden of KPMG Sweden analyse a ruling that challenges the Swedish Tax Agency’s approach to revaluing intragroup services where no comparable market exists