Issues
ITR has partnered with leading Swiss tax specialists to consider the most pressing taxation issues facing the country.
With the M&A market booming, ITR has partnered with correspondents from firms around the globe to provide a guide to the deal structures being employed and tax authorities' responses.
ITR has partnered with global TP leaders from Deloitte to discuss transfer pricing controversy around the globe, and to share advice on how to navigate an increasingly uncertain and risky TP landscape.
As Latin American countries increasingly align with the OECD, transfer pricing (TP) remains a hot topic, while jurisdictions continue to introduce tax reforms in the wake of COVID-19. ITR’s correspondents offer an overview.
Sponsored
Sponsored
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Sponsored by Webber WentzelChanges made last year to South Africa's dividend stripping rules have effectively eliminated the ability of group companies to make use of the rollover relief provisions that historically have allowed qualifying liquidations or deregistration of group companies (both local and foreign) to be done on a tax-neutral basis. -
Sponsored by Garrigues PortugalA recent Portuguese Arbitration Court decision (Case 639/2017-T), dealing with the application of the exemption method to foreign-based liquidation proceeds for non-habitual tax residents serves as a good illustration of how this domestic exemption works.
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Sponsored by Dhruva AdvisorsThe Income-tax Act, 1961 was amended in 2012 such that non-resident taxpayers are not entitled to claim relief under a tax treaty unless they obtain a tax residency certificate (TRC) from their country of residence. But a recent court ruling has changed the situation.
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