Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations
India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
The UK-based big four spin-off firm has hired Marc Lien, who declared that most AI in professional services today is ‘cosmetic’
Projected revenue losses and exemption requests are harming the project’s capability and viability
Sponsored
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Sponsored by DeloitteJess Williams, Jimmy Man, and Olivier Hody of Deloitte explain how tax can be elevated from a post-close support function to a value-realisation tool in M&A transactions through quick wins and longer-term actions -
Sponsored by DeloitteDeloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead
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Sponsored by DeloitteDave Yaros, tax principal, Deloitte Tax LLP
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As Japan moves towards a new transfer pricing (TP) regime, companies fear the increasing use of the profit split method could erode the arm’s-length principle (ALP).
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The OECD has stunned the tax world by signalling countries’ willingness to consider radical steps to drag the global corporate tax system into the 21st century by addressing the challenges of the evolving world economy.
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China has introduced a profit monitoring mechanism that taps into big data analysis to carry out risk assessments so that more targeted administrative action can be taken against large taxpayers.
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The lack of comparables remains one of the biggest challenges for transfer pricing (TP) professionals, especially in low capacity countries. Gela Barshovi explains how the country ceiling principle may help companies and tax administrations to determine risks, benchmarks and establish comparables.
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Russian legal entities that make capital gains from the sale of shares are eligible for a 0% tax rate, yet the criteria for satisfying this arrangement may not always be so simple.
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The UK’s tax authority, HM Revenue and Customs (HMRC), has recently published updated guidance on the tax treatment of cryptoassets. Kate Habershon, Neil McKnight and Nelson Yates II of Morgan, Lewis & Bockius examine the guidance and how it compares to the US’s perspective.
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Jon Feldhammer has joined Baker Botts’s San Francisco office as a tax litigation partner.
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Businesses shouldn’t think about compliance with EU digital tax proposals, but instead influence the conversation and ensure governments aren’t hitting them by accident, say tax executives, advisors and lobby groups.
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A well-constructed and executed global operational transfer pricing (OTP) framework is essential to properly manage financial statements, taxes and reputational risk for multinational enterprises (MNEs), writes Richard Goldberg, former tax director at Mitsubishi Financial Group.
