Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
New reforms represent the most seismic shift in Canadian TP legislation since its enactment and a clear inflection point for MNEs, ITR has heard
Spain did not transpose EU VAT rules for SMEs or works of art; in other news, an increased VAT threshold came into force in South Africa
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
Sponsored
-
Sponsored by Tax PartnerMonika Bieri and Daniel Schönenberger of Tax Partner use a Swiss lens to examine how workforce mobility is reshaping transfer pricing models, and why the location of key decision‑makers is becoming a critical tax risk -
Sponsored by CuatrecasasJosé Maria Cabral Sacadura and Vicente Pirrone of Cuatrecasas analyse the Sofina line of CJEU case law and assess when Portuguese withholding tax rules entitle foreign loss‑making companies to reimbursement
-
Sponsored by Svalner Atlas AdvisorsPatrik Sedlar and William Berntö of Svalner Atlas Advisors draw on case law to question whether the Swedish Tax Agency’s stance on recharacterising intra‑group intangible property licensing arrangements conflicts with the OECD Transfer Pricing Guidelines
-
The transitional period will allow MNEs to report GloBE calculations at a jurisdictional level rather than on a constituent entity basis.
-
One of the safe harbours may smooth the path to US enactment of pillar two legislation in years to come.
-
Businesses have until September 1 to comment on the implications of amount B for the future of the arm’s-length principle and transfer pricing rules.
-
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2023 Europe Middle East & Africa Tax Awards – winners to be announced on September 27th
-
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2023 Asia-Pacific Tax Awards – winners to be announced on September 27
-
The Women in Business Law Awards is excited to present the shortlist for the 2023 Asia-Pacific Awards.
-
Access to more company information, increasingly aggressive tax authorities, and global reform negotiations nearing their end are just some of the factors behind a heightened risk of controversy, say the tax directors and practitioners who spoke to Ralph Cunningham.
-
The European Commission and the IRS continue to lock horns with some of the world’s largest firms over issues including profit-shifting and transfer pricing. Here are ITR’s top tax disputes of 2023 so far.
-
Businesses may be more likely to seek out alternative dispute resolution processes to reduce the chances of a lengthy court battle, rather than use traditional options such as APAs and MAPs.
