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The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, and rejects protection for indirect transfers and tightening conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
Partners want to join Ryan because it’s a disruptor firm, truly global and less bureaucratic, Tom Shave told ITR
The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
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Sponsored by MDDPMarta Klepacz of MDDP explains that the application of transfer pricing changes to third-party transactions has placed a burden on taxpayers, not least because of the difficulty in identifying the suppliers in indirect transactions. -
Sponsored by QCG Transfer Pricing PracticeMiguel Ángel García Piña of QCG Transfer Pricing Practice explains the complications for Mexican taxpayers now that business reason has been firmly embedded as a concept under recent reforms, but with uncertainties remaining.
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Sponsored by KPMG Hong KongLewis Lu and John Timpany of KPMG China discuss the implications of a proposed refined foreign source income regime in Hong Kong for constituent entities of multinational enterprises.
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