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The Netherlands-based bank was described as an ‘exemplar of total transparency’; in other news, Kirkland & Ellis made a senior tax hire in Dallas
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said
The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
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Sponsored by Hager & PartnersFollowing a public consultation on draft regulations designed to provide operational guidance on transfer pricing in line with the international evolution that has occurred at OECD level (the BEPS project), the Italian Ministry of Economy and Finance issued the Decree of May 14 2018 on the application of the arm's-length principle based on international best practices (published in the Official Gazette number 118 of May 23 2018). -
Sponsored by NeraThe OECD BEPS initiative has introduced numerous likely challenges to transfer pricing structures defended through application of the transactional net margin method (TNMM). This article focuses on the economic analysis enhancements needed to make TNMM-type transfer pricing solutions sustainable in the future.
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Sponsored by KPMG ChinaIn recent years the Chinese government has progressively replaced administrative pre-approvals for various tax treatments and regulatory licences with tax authority record filing requirements. This has been coupled with more targeted and effective procedures for follow-up audit and review.
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