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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 Deloitte MexicoDeloitte’s Simon Somohano and Eduardo Campos explain the Mexican tax authority’s latest non-binding transfer pricing criteria, which some have labelled heavy handed. -
Sponsored by Deloitte South AmericaSouth America is in the throes of implementing the OECD BEPS project with new regulations emerging from every corner of the region, write Deloitte’s Latin America Countries Organisation practitioners. The developments clearly signal a tougher stance by authorities on transfer pricing and indicate that advance pricing agreements may be a key tool of the future.
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Sponsored by Dhruva AdvisorsThe subject of transfer pricing (TP) has gained a great deal of momentum globally over the past couple of years. Most of the OECD and G20 countries have implemented TP legislation even before the BEPS initiative and have issued further regulations considering the recommendations of the BEPS Action Plan reports.
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