June 2018
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Sponsored by KPMG USMark Martin and Cameron Taheri of KPMG take a closer look at the IRS's APA statistics for 2017.
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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 KPMG ChinaFollowing on from the annual meeting of China's Parliament, the National People's Congress (NPC), in early March, the Chinese government has been implementing a string of tax reform measures, the most recent of which was the VAT rate reductions.
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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.
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Sponsored by NeraIn the first of a series on transfer pricing technical challenges and solutions to changing economic and regulatory environments for global multinationals, this article focuses on the remuneration of top management functions in the inter-company context.
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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.
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Sponsored by Dhruva AdvisorsThe issue of whether a waiver of loans results in taxable income for the borrower has been a controversial one in India.
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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.