The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
The expansion introduces ‘business-level digital capabilities’ for tax professionals, the US tax agency said
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
Partners want to join Ryan because it’s a disruptor firm, truly global and less bureaucratic, Tom Shave told ITR
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Sponsored by GNV ConsultingAhdianto Ah and Aditya Nugroho of GNV Consulting explain recent Indonesian tax reforms affecting business restructurings, treaty access, and enforcement
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Sponsored by GNV ConsultingAhdianto Ah and Aditya Nugroho of GNV Consulting summarise an extension of the government-borne incentive, new risk-based taxpayer compliance supervision rules, and revised mutual agreement procedure guidelines
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APAC tax teams that engage proactively with authorities can still face difficult decisions on how to approach their compliance obligations in different countries.
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Kuwait signed its first tax treaty with a Gulf Cooperation Council country, while the IRS and Western Digital have settled a $1.6 billion transfer pricing dispute.
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Tax directors warned Brazil’s alignment with the OECD guidelines could alter the way corporations use comparables and approach royalties in TP.
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Businesses say pillar one sourcing rules lack simplicity and could lead to administrative burden costs, following the OECD’s progress report in July.
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Some businesses are bucking the outsourcing trend and bringing certain tax functions back in-house as scrutiny by tax authorities increases.
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Tax directors have warned businesses of the potential pitfalls when integrating different tax operations, amid record high mergers and acquisitions activity.
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Microsoft and Unilever raise concerns in the OECD consultation on pillar one, while the Brazilian government is set to table a bill on transfer pricing reform.
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Asia-based companies fear the way pillar two will be implemented in the region as it could roll back key incentives, especially in insurance and manufacturing.
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Companies are adopting tax insurance plans to cover the TP risks of restructuring following COVID-19, the supply chain crisis and Russia-Ukraine war.
