Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Partners at both firms have voted in favour of the tie-up, which marks ‘the largest law firm merger in history’
The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
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Sponsored by CuatrecasasAndré Areias and Raquel Santos Ferreira of Cuatrecasas scrutinise Portugal’s use of increased municipal property tax on vacant properties and question whether extreme rate multipliers and weak procedural safeguards can withstand constitutional scrutiny -
Sponsored by MFA Legal & TechSamuel Fernandes de Almeida and Ana Rita Carvalho of MFA Legal & Tech explain how a Portuguese binding ruling fuels the emerging dispute with Spain over non-habitual tax residents
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Sponsored by DeloitteLisa Zajko, indirect tax partner, Deloitte Canada
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Tax directors say that taking a collaborative approach to digital taxation can help with managing tax authority attitudes and simplify compliance, while awaiting a multilateral solution.
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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).
