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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The Rising Stars Awards research cycle has now opened across all three regions
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In the final quarter of 2021, the CJEU ruled in favour of a pharmaceutical company, the US dropped its tariff threat against European countries over DSTs, and Uber faced another blow in the UK.
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ITR looks at the transfer pricing (TP) challenges set to rise in 2022 as the Omicron variant creates more disruption for the global tax system.
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The OECD released model rules for its 15% global minimum corporate tax to define the limits to national tax and trade incentives for large companies. Yet, there are protections for corporate investment in the model rules too.
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Mariana Morais Teixeira of Morais Leitão discusses Portugal’s tax framework for donations to non-resident entities.
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The OECD’s model rules for a 15% global minimum tax are already circulating among government tax advisors, but the public draft is due on December 20. The model will set up drafts for national rules, which an EU directive – also due in December – supports.
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The UK tax authority’s latest transfer pricing (TP) consultation demonstrated an appetite for stronger OECD-aligned guidelines. Yet the changes will also increase the burden of proof for large businesses.
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The latest outcome from the European Court of Justice (CJEU) on a directive 2018/822 (DAC6) case shows that companies can avoid penalties for intrusive data inquires when EU tax authorities target individuals over groups.
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The OECD-led pillar one and pillar two tax deal will not bring an end to global tax competition, but tax directors and policymakers agree that it will change how countries compete.
