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.
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Sponsored by MathesonThe Irish Revenue Commissioners (Revenue) were successful in arguing before the Appeal Commissioners that no general trading deduction should be available for excess foreign tax incurred on royalties where an Irish tax credit was claimed for part of the foreign tax withheld. The decision is being appealed to the High Court. -
Sponsored by KPMG ChinaThe long awaited Announcement 9 has been released by the State Administration of Taxation of China (SAT). Effective from April 1 2018, Announcement 9 replaces Circular 601 and Announcement 30, both of which are key circulars setting out the rules for foreign investors claiming tax treaty benefits on their Chinese-sourced dividends, interest and royalties (passive income).
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Sponsored by Deloitte SwitzerlandOn March 21 2018, the Swiss Federal Council sent to the Swiss Parliament the dispatch on the draft legislation for the so-called Swiss Tax Reform Proposal 17.
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