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 Deloitte UKJohn Henshall and Achim Roeder explain why it would be unwise to underestimate the impact of business restructuring. The impact extends to the discussion on the revision of chapter VI of the OECD transfer pricing guidelines on intangibles.
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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.
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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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