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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

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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.
  • A new ‘profit diversion compliance facility’ (PDCF) announced by the UK tax authority aims to encourage companies to bring their transfer pricing (TP) arrangements in line with HMRC’s interpretation of the arm’s-length principle, writes Ben Regan, transfer pricing partner at EY.
  • Businesses are at risk of being caught unaware if they ignore the continuous amendments to VAT regimes across the Gulf Cooperation Council (GCC) member states, tax heads warn.
  • Advisors and fund managers expect more qualified opportunity funds (QOFs) to be organised as real estate investment trusts (REITs) to maintain key US tax benefits under the TCJA's qualified opportunity zone (QOZ) programme and avoid locking in investments.
  • The rate of change in the tax regulatory environment in recent years has been rapid, arguably more so than at any other time in recent history. Heads of tax are competing with colleagues in other functions for a share of finite budgets. The challenge is to show value for money, writes Sandy Markwick, head of the Tax Director Network at Winmark.
  • Tax directors examining tax technology opportunities know that regulating internal data and establishing a global reporting standard is a must when it comes to the successful cross-border adoption of any digital platform. Blockchain is no different.
  • Italy’s new e-invoicing regime came into effect on January 1. Companies expected teething trouble, but the early signs are positive and the changes should lead to long-term benefits.
  • For all companies that sell to US consumers without a physical presence in states, 2018’s Wayfair decision was a bolt from the blue. But the work of complying with ‘economic nexus’ rules in every taxing jurisdiction will be an ongoing project, not a one-off effort.
  • Tax transparency initiatives such as the CRS, AEOI and FATCA, and the upcoming mandatory disclosure rules, are having a profound impact on the operations and IT infrastructure of financial institutions (FIs) worldwide. Ronald Frey, chief product officer of the RegTech product unit within BearingPoint, discusses how these are creating trends towards data alignment and centralisation, and are changing the role of FIs and wealth managers in cross-border tax reporting.
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