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 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. -
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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Sponsored by Fenwick & WestThe 2017 Tax Act added new Section 864(c)(8) on the sale of a partnership interest. The provisions introduce rules that were disputed in Grecian Magnesite v Commissioner.
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