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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IFA President Murray Clayson predicts a greater international appetite for a digital profits-based tax and an extended PE concept as he talks to International Tax Review about the 72nd Congress in Seoul.
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Transfer pricing continues to be one of the Chinese State Administration of Taxation’s key focus areas, write Cheng Chi, Rafael Triginelli Miraglia and Choon Beng Teoh of KPMG. New policies and methodologies are being examined post-BEPS to strengthen the SAT’s monitoring of MNEs’ TP.
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McDermott Will & Emery has responded to the increasingly complex US tax environment by hiring three state and local tax lawyers.
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Coca-Cola’s profit split method may result in the soft drinks giant having to pay a $3.3 billion tax bill if the US Tax Court decides to reverse its earlier decision on the Medtronic case.
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The rise of integrated supply chains, complex organisational structures and inter-company transactions, means the harmonious interplay between customs valuation and transfer pricing has never been more important, writes Leonie Ferretter of KPMG. However, across the Asia Pacific region, we continue to see disparity in how TP is treated from a customs perspective.
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The Tokyo District Court recently issued two judgments regarding transfer pricing (TP) cases, both in relation to the treatment of intangibles. These decisions provide insights into how the Japanese tax authorities will evaluate intangibles when dealing with TP issues in audits going forward, explain Yutaka Kitamura and Jun Sawada of Deloitte.
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There is a lot of discussion about the future of the financial services sector, write Ralf Heussner and Enrique Marchesi-Herce of Deloitte. New technologies and automation, a changing regulatory landscape, and the entry of new market players are reshaping the industry. On top of this, the industry is undergoing further consolidation while having to respond to shifting customer demands and new distribution models.
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We have seen a strong start to 2018 in terms of M&A activity, write Jon Vine and Greg Smith of Deloitte. Mergers and acquisitions invariably involve a range of complex tax issues. While these continue to include matters such as acquisition structuring, financing and structurally integrating the acquired business, the complexity and range of transfer pricing (TP) issues which arise in the M&A context should not be underestimated.
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Welcome to International Tax Review's guide to intangible assets, published in association with Deloitte. In today's digital revolution, intangible assets are as central to the business function as steam-powered machines were during Industrial Revolution.
