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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Awards
The ‘big four’ firm scooped over 60 honours at a lively ceremony held at The Londoner hotel, including both EMEA and APAC Tax Advisory Firm of the Year
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The firms received fees for referring clients to the avoidance scheme, HMRC said; in other news, Freshfields’ former tax head has lost his fraud conviction appeal
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ITR spoke to two US TP experts about the long-running dispute, with one arguing that the case highlights ‘weaknesses’ with the comparable uncontrolled transaction method
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The new practice, which features former ‘big four’ experience, already has over 20 team members
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Speakers from companies including Uber and Stripe told the inaugural AI in Tax Forum to brace for impending changes to how advisers work
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Authors from Khaitan & Co dissect a ‘welcome’ ruling, which found that the mere existence of a tax benefit would not, by itself, warrant a principal purpose test
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Over two-thirds of survey respondents back the continuation of the UK’s digital services tax, research commissioned by the Fair Tax Foundation also found
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Given the US/G7 pillar two deal, the OECD is in danger of being replaced by the UN as the leading global tax reform forum
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Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment
