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Transfer Pricing
features sponsored features special focus local insights
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Hans Grimbergen and Ivo Middelink of Ernst & Young Belastingadviseurs argue that the Dutch secretary of state has not gone far enough in overhauling the tax treatment of interest on acquisition debt and look at the various tax aspects of M&A which are causing problems in the Netherlands.
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Abhishek Shah of Ernst & Young analyses the indirect tax proposals of the Indian budget and finds there is not much good news for taxpayers.
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On February 13 2013, the OECD released a report on tax planning by multinationals that reduces group corporate tax liability to an unacceptably low level, as a first step against base erosion and profit-shifting (BEPS). In the preceding months Starbucks, Google and several others were publicly attacked for not paying their “fair” share. Johann Muller, a member of the international corporate taxation department at the Danish Tax Authority – submitting this article in a personal capacity in advance of the OECD Working Party No 6 meeting in March – examines the issues that need to be addressed when looking at examples 1 and 2 to Annex C of the BEPS report.
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