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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 Transfer Pricing GlobalEnergy multinationals have complex, international supply chains that contract a host of specialist companies in the process of bringing vital commodities to market, making intellectual property attribution ambiguous. In this primer, Deloitte’s Nick Gaudioso, Randy Price, Nadim Rahman and John Wells give an overview of the energy excavation and production process to understand the tax ramifications. -
Sponsored by Deloitte Transfer Pricing GlobalTransfer pricing (TP) litigation surrounding the energy and resources (E&R) sector has increased drastically over the past two years. While determining the owner of the commodity price risk has drawn increased attention, Deloitte’s Mark Barker and Aengus Barry discuss how tax authorities predominantly employ the comparable uncontrolled price (CUP) method in any TP dispute.
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Sponsored by Deloitte Transfer Pricing GlobalOffshore marketing hubs are becoming increasingly commonplace for Australian resource firms in Asia. Deloitte’s John Bland and Milla Ivanova discuss what factors may trigger increased regulatory scrutiny for a multinational under the Australian Taxation Office’s (ATO) risk ratings.
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