The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns
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’
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Sponsored by Lakshmikumaran & SridharanThe Tiger Global Supreme Court ruling weakens the status of tax residency certificates under tax treaties and increases substance‑based scrutiny, say S Vasudevan, Bharathi Krishnaprasad, and Krishna Laasya V of Lakshmikumaran & Sridharan
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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
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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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John LaBorde has joined Andersen Tax as managing director of the firm’s Houston office.
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The US Ninth Circuit Court’s withdrawal of its July 24 decision in Altera has prevented US transfer pricing rules from going into meltdown – for now.
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Real-time compliance tools offer tax authorities a new means of detecting un-taxed income, but the risks of data exchange may leave both governments and companies vulnerable to cyberattacks.
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BDO and Grant Thornton’s South African outfits have announced plans to merge in the fourth quarter of 2018. The merger is set to create the largest mid-tier accounting firm in the country.
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Recent changes in the business environment and the financial situation of the Japanese government have affected the Japanese taxation environment and transfer pricing regulations, explain Jun Tanaka, Nobuhiro Tsunoda and Yosuke Suzaki of KPMG in Japan.
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Transfer pricing is on the radar again in the Philippines, reports Maria Carmela Peralta of KPMG. It’s too early to tell whether the lengthy discussions taking place will bear fruit and the Philippines will have something other to show than its 2013 TP regulations, which the Philippine Bureau of Internal Revenue (BIR) is perceived to have overlooked.
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Almost two decades after the introduction of transfer pricing regulations in 2001, the Indian TP space has evolved and matured immensely, write Manoj Pardasani, Hasnain Shroff and Hardev Singh of BSR & Co. Today, India’s TP regulations are in line with international TP principles and the Indian government is continuing to align the TP regulations with global best practices.
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Indonesia completed the last step in the introduction of new transfer pricing regulations late last year, report Iwan Hoo, Aaron Brunier and Fachrur Rifqi Nugroho of KPMG. While the regulations covering the master file, local file and country-by-country reporting were issued in 2016, the implementing regulations for CbCR were not completed until late December 2017.
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The OECD’s BEPS initiative has sparked a global focus on MNEs and their transfer pricing. In recent years, writes Tony Gorgas of KPMG Australia, there has been a profound change in the ASPAC region as governments and tax administrations seek to ensure multinationals pay their fair share of tax in line with economic and value creation.