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Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal
The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player
The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions
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Sponsored by NeraIn the first of a series on transfer pricing technical challenges and solutions to changing economic and regulatory environments for global multinationals, this article focuses on the remuneration of top management functions in the inter-company context. -
Sponsored by PwC ChileOver the years, the Chilean IRS has issued a number of rulings on how to apply Article 12 (royalties) of double tax agreements (DTAs). These have been particularly in regard to the taxation over payments made from Chile to overseas countries for distribution rights, and their characterisation as intangible property.
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Sponsored by Russell McVeaghThe New Zealand government has announced a non-refundable tax credit of 12.5% of eligible research and development (R&D) expenditure (R&D credit), from April 2019.
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