Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Ian Halligan previously led Baker Tilly’s international tax services in the US
Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks -
Sponsored by VdAThe regime has modernised the taxation of employee equity, but several lingering shortcomings leave room for enhancement, say João Riscado Rapoula, Miguel Gonzalez Amado, and Ana Francisca Ribeiro of VdA
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Sponsored by PwC ChileSandra Benedetto and Paula Campusano of PwC Chile analyse recent Chilean Internal Revenue Service rulings that adopt a new methodology compared with the criteria set in previous administrative instructions
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Tax directors doubt that there will be an agreement on the OECD’s digital tax proposals in 2021, but want to see a commitment to address unilateral measures, tackle double taxation risks and finalise the scope as a minimum.
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Miguel Pimentel and Ana Carrilho Ribeiro of Morais Leitão consider conflicting judicial decisions and address the scope of a stamp duty exemption applicable to financial institutions.
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The role of fund managers and financial technology in the financial services (FS) sector is keeping negotiations about partial inclusion on the table for more than 137 countries participating in the digital tax debate.
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In the week that Coca-Cola lost its transfer pricing battle with the IRS, the EU and OECD have come under attack for failing to solve digital tax just as the US is preparing new sanctions.
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The US will soon reveal the results of trade investigations on three countries over the introduction of digital services taxes (DSTs), likely providing the base for retaliatory tariffs.
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A report by the Tax Justice Network (TJN) argues that EU and OECD efforts on digital tax reforms should be superseded by a UN multilateral tax convention. It also proposes an excess profit tax, public country-by-country reporting (CbCR), and more accountability for EU tax havens.
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Coca-Cola faces a hefty tax bill after the US Tax Court found the soft drinks company had routed too much profit to its foreign operations in a profit split arrangement, rather than its US parent company.
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Many taxpayers are weighing up the strengths and weaknesses of their advance pricing agreements (APAs) and seeking alternatives as companies worry about the impact of the OECD digital tax proposals on permanent establishments (PEs).
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Breaking new ground: Up and coming professionals from across the Americas shortlisted for the 2020 Rising Stars Awards
