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Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Moore, founding partner of the Chicago tax boutique which bears her name, shares her career wisdom for ITR’s new Women in Tax interview series
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Sponsored by Deloitte USIncreased globalisation has resulted in significant pressure on US multinationals to take a more global view not only of their operations but also of the manner in which they hold, manage, and develop intangible assets. As a result of these drivers, transferring intangible property (IP) out of the US group to a controlled foreign corporation (CFC) may make sense, explain David Cordova, Gretchen Sierra and Douglas Cowan. -
Sponsored by Deloitte USMarco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach.
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Sponsored by Deloitte USAs energy firms discover and exploit new reserves which require significant amounts of financing, tax authorities have increased their focus on the intra-group financing transactions of such companies. Randy Price, Nadim Rahman and Bill Yohana of Deloitte investigate why the materiality of these transactions may have also increased taxation authority interest in the intra-group financing transactions of energy firms.
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