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Direct Tax
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When allocating corporate costs for intra-group services, the Norwegian Tax Authorities has in recent years been claiming that allocations based on opex/capex must be adjusted for local price- and cost levels by applying a price level indicator (PLI). Jan Jansen and Joachim Bjerke of BA-HR explain what this means for the Norwegian energy sector.
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The adoption of new accounting standards based on IFRS as of 2008, and the effects of such new rules for Brazilian taxpayers, is among the most relevant tax matters under discussion in Brazil, explain Paulo Rogerio Sehn and Simone Dias Musa of Trench, Rossi e Watanabe Advogados.
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Back in January, the European Commission launched a public consultation on the double non-taxation of cross-border companies. The Commission hopes the consultation will gauge the full scale of the problem and see where the main weaknesses lie and will develop a policy response before the end of 2012. Jack Grocott speaks to Philip Kermode, Director for Direct Taxation in DG Taxation and Customs, about what he hopes the consultation will achieve and what it means for taxpayers.
Sponsored Features
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Sponsored by KNAV IndiaIndia’s transfer pricing overhaul expands safe harbours at scale and accelerates advance pricing agreements alongside the statutory recodification of the Income-tax Act, report Uday Ved, Hetav Vasani, and Jainesh Nahar of KNAV
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Sponsored by insightsoftwareJoin KPMG and insightsoftware on June 25 as ITR presents a free webinar on the evolving role of tax professionals and how technology is driving the transformation
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Sponsored by DeloitteJess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions
Special Focus
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Sponsored by YulchonSeveral South Korean transfer pricing cases have established clearer judicial standards emphasising robust comparability analysis and stronger functional and economic evidence. Yulchon tax partners provide practical insights for navigating the heightened requirements
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia examine how geopolitical conflict and economic volatility are reshaping transfer pricing risk and enforcement, with a particular focus on Southeast Asia and Indonesia
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Sponsored by Tax PartnerMonika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk
Local Insights
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Sponsored by Lakshmikumaran & SridharanIndia’s Finance Act, 2026 introduces a tax framework for foreign companies using local data centres but leaves several questions unresolved, say S Vasudevan, Prachi Bharadwaj, and Loveena Manaktala of Lakshmikumaran & Sridharan
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Sponsored by Pérez-LlorcaNicolle Barbetti of Pérez-Llorca explains how the Capitalisation of Companies Incentive has reshaped Portugal’s corporate financing landscape and highlights how binding rulings have clarified key issues in its application
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Sponsored by PwC ChileNatalia Núñez and Antonia Valdés of PwC Chile analyse the new bill’s tax implications for a key sector, considering the provisions of the Mining Royalty Law