Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
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
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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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Governments around the world are expected to implement OECD plans for digital tax reform, but these plans are far from the only changes on the agenda.
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The OECD’s business group has criticised pillar two’s model rules for failing to address at least one technical issue. The rules will direct legislation in 137 countries introducing pillar two by 2023.
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The Omicron wave has produced more supply chain disruption for companies around the world, just as there has been a surge in IP transactions. TP teams have to stay ahead of the pace of change.
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Countries including the UK are considering cutting VAT on domestic energy bills to mitigate rising prices due to the energy crisis. Meanwhile, energy firms could face a windfall tax.
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ITR invites tax firms, in-house teams and tax professionals to make submissions for the 2022 ITR Americas Tax Awards, Asia-Pacific Tax Awards and Europe, Middle East and Africa Tax Awards
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The European Commission published tax initiatives in December including a directive to tackle shell entities. This could start a “cottage industry” for advisors to sell tax structures to multinational enterprises (MNEs).
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This week Scottish oil company Cairn Energy ended its battle with the Indian government in exchange for a refund of more than $1 billion in back taxes.
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The main themes that emerged from the most-read articles were COVID-19, court case analysis, digital economy, industry specific articles, M&A, tax reform and transfer pricing.
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Cameco, Engie, and Nike headlined the biggest corporate transfer pricing (TP) cases from 2021, and 2022 could offer more court rulings that revise in-house TP practices at other large multinational enterprises (MNEs).
