Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed
The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another
Sponsored
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Sponsored by DeloitteDeloitte tax partners examine how tax authorities in Colombia, Peru, Ecuador, and Venezuela are shifting transfer pricing audits from pricing analysis to economic substance and evidentiary support -
Sponsored by DeloitteSilvana Blanco, Joel Morante, and Felipe Prado of Deloitte examine how transfer pricing is being reshaped in Argentina, Chile, and Uruguay through closer scrutiny of governance, value creation, operating models, and pillar two implications
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Sponsored by Mascareño Vargas – AsesoresMauro Mascareño, Carlos Jorge Vargas, and Rodrigo Gómez Sánchez of Mascareño Vargas – Asesores explain how Paraguay’s territorial tax system, investment incentives, and residence pathways are attracting foreign investors amid strong economic performance
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Overall revenues and average profit per partner also increased in the UK, the ‘big four’ firm revealed
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Increasingly complex reporting requirements contributed towards the firm’s growth in tax, it said
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Sector-specific business taxes, private equity tax treatment reform and changes to the taxation of non-residents are all on the cards for the UK, authors from Herbert Smith Freehills Kramer predict
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The UK’s Labour government has an unpopular prime minister, an unpopular chancellor and not a lot of good options as it prepares to deliver its autumn Budget
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Awards
The firms picked up five major awards between them at a gala ceremony held at New York’s prestigious Metropolitan Club
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The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
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Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
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If the US doesn't participate in pillar two then global consensus on the project can’t be a reality, tax academic René Matteotti also suggests
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If it gets pillar two right, India may be the ideal country that finds a balance between its global commitments and its national interests, Sameer Sharma argues
