Feature
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
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Sponsored by DeloitteInterview with Adham Hafoudh, partner, Tax & Legal, Deloitte Czech Republic -
Sponsored by CuatrecasasA recent ruling curbs formalistic proof requirements in EU cross-border pension fund taxation while strengthening the substance over form and ‘equality of arms’ concepts, say João Rodrigues, Liliana Piedade, and Francisco Ludovino Reis of Cuatrecasas
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Sponsored by CMSTax authorities in Europe are stepping up their transfer pricing focus. A podcast held by ITR in collaboration with CMS explores what multinational enterprises can do to mitigate risk
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