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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Revenue authorities are asking multinational enterprises (MNEs) for more details during advance pricing agreement (APA) negotiations because of the BEPS project, which requires companies to have a more robust APA strategy.
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As the environmental impact of non-recyclable plastic waste becomes an area of tax policy focus, tax professionals foresee that this will become a new area for litigation.
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Companies turn to bolt-on system solutions to manage a rise in audits after a year of unexpected transfer pricing (TP) adjustments due to the COVID-19 pandemic.
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The Court of Justice of the European Union (CJEU) has ruled that Sonaecom can partially deduct the VAT incurred in an aborted deal, placing a limit on deductions based on how the capital was raised and used.
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Multinational enterprises (MNEs) should maintain documentation, track the location of their employees, and allow company directors to delegate responsibility to minimise permanent establishment (PE) and double taxation risks.
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Taxpayers continue to face mounting uncertainty over the coming break between the EU and the UK tax systems, while the Glencore case offers some reassurance to multinationals with similar arrangements.
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HM Revenue & Customs (HMRC) is expanding its Making Tax Digital (MTD) regime to include corporate tax disclosures, but some taxpayers expect “teething challenges” following a number of problems in earlier iterations of the regime for VAT reporting.
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The OECD may find the US to be more engaged once President-elect Joe Biden takes office. However, the interests behind US policy have not changed and tariffs will stay on the table.
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Transfer pricing (TP) disputes may increase in Central and South America as tax authorities chase revenue and adopt new tax reporting standards in line with OECD guidelines.
