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Transfer Pricing
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The new double tax treaty between Argentina and Spain has been in place for more than two months, having been signed in March (with retrospective effect to January 1 2013) after the unexpected termination of the old accord. Guillermo Teijeiro, of Teijeiro & Ballone Abogados, looks at why the old treaty was replaced, and analyses the new agreement in the context of Argentina’s wider treaty network.
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Undeniably, the spotlight is increasingly falling on the tax affairs and tax payments of multinational corporations. While tax departments retain a duty to shareholders to minimise the tax liability, the debate around such tax strategies has evolved faster in the years since the global financial crisis than ever before. Matthew Gilleard analyses what this evolution means for today’s tax director.
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By 2025, four of the 10 largest economies in the world will be in Asia – China, India, Japan and Indonesia. Asia will account for approximately half of the world’s economic output. This is why the 21st Century is increasingly being recognised as the “Asian Century” – a period of sustained economic growth and prosperity, already taking place – and expected to continue throughout the region. Tim Gillis and Lachlan Wolfers of KPMG look at whether this growth will also see the rise of indirect taxes.
Sponsored Features
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Sponsored by insightsoftwareJoin Grant Thornton and insightsoftware on April 23 for a free ITR webinar exploring how flexible tax software aligns with your existing processes, enabling smoother adoption, integration, and phased implementation across complex organisations
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Sponsored by BDO IndiaJoin ITR for a free webinar on February 4 as senior tax practitioners from BDO India analyse a highly significant ruling by the Indian Supreme Court
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Sponsored by DeloitteInterview with Candy Ye Tang, tax and business advisory leader, Deloitte China
Special Focus
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Sponsored by EY Central AmericaAntonio Ruiz and Alejandra Arguedas of EY Central America, Panama and Dominican Republic explain how tax, geopolitical factors, and trade agreements shape foreign investment in Central America, offering guidance for companies navigating the region
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Sponsored by DDTC ConsultingDavid Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals
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Sponsored by DeloitteEddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges
Local Insights
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks
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Sponsored by VdAThe regime has modernised the taxation of employee equity, but several lingering shortcomings leave room for enhancement, say João Riscado Rapoula, Miguel Gonzalez Amado, and Ana Francisca Ribeiro of VdA
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Sponsored by PwC ChileSandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions