Tom Goldstein’s attempt to overturn his tax conviction was shot down; in other news, Deloitte promoted several tax partners in Italy
The tax advisory firm becomes the latest member of the Andersen Global network, which has more than 50,000 professionals worldwide
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
Sponsored
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Mirabella of Gatti Pavesi Bianchi Ludovici analyse a recent Italian Supreme Court decision that confirms the application of the three-test beneficial ownership framework to treaty-protected royalty payments -
Sponsored by MFA Legal & TechBárbara Miragaia of MFA Legal & Tech argues that the regime’s restrictive eligibility rules and limited relief for intra-group transactions may constrain its practical benefits
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on the beginning of the tax reform implementation phase and concerns about pending regulation
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Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed
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In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
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ITR's latest podcast considers how transformational the buyout could be in Ryan's quest for global advisory reach and analyses a recent boom in demand for private client advisory services
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The event comes at an important moment for professionals dealing with practical realities related to this practice area
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Germany’s dogmatic restriction of third-party investment in tax advisory firms will only serve to slow down innovation and access to justice
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The Irish government has been told that it’s spending too much of its corporation tax receipts and should instead focus on running bigger surpluses; plus, the IRS is set to merge tax practitioner offices
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A company risks double taxation, penalties and inquiry cost if it submits a form with anomalies under the new system, Asker Ali also tells ITR
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Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
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The scandal has come just three years after the PwC tax leaks controversy and has prompted KPMG’s Australian chief executive to resign
