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
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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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Tax advisers in Brazil are rising above the country’s notoriously complex tax system to deliver high-quality advisory services, ITR’s exclusive in-house data reveals
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ITR’s data has highlighted the US firm’s ambition to become America’s ‘premier’ tax player via a concerted partner recruitment strategy
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Jaap Zwaan’s arrival continues a recent streak of A&M Tax investing in the region; in other news, the US and Japan struck a deal that significantly lowered tariff rates
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In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present
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France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard
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In an exclusive interview with ITR, Ian Gary calls for a central public CbCR database and bemoans the US’s lack of involvement in international tax transparency
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Reckitt Benckiser is to divest its Essential Home business, which includes more than 70 brands, to private equity firm Advent International
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In the first of a new series of weekly opinion pieces, ITR Editor Tom Baker reflects on the OECD’s attempts to sanitise the US’s brazen pillar two negotiations
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The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR
