LEAD ARTICLE
LEAD ARTICLE
Sponsored
Sponsored by
Crowe Valente/Valente Associati GEB Partners
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptWith transfer pricing principles becoming increasingly important as start-ups expand, Nouran Ibrahim and Maureen Guirguis of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the salient points and how to meet the challenges
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptYasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt conclude a two-part series on transfer pricing audits in Egypt by anticipating the changes under the newly established automated process
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Sponsored by Saleh, Barsoum & Abdel Aziz – Grant Thornton EgyptIn the first article of a two-part series on transfer pricing audits in Egypt, Yasmine Hammad, Haidy Elaasser, and Mahmoud Ashraf of Saleh, Barsoum & Abdel Aziz – Grant Thornton Egypt explain the current process
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Sponsored by GNV ConsultingBenjamin P Simatupang, Dwipa Abimanyu Dewantara, and Fajar Ramadhani of GNV Consulting highlight updated regulations and mandatory implementation of the Customs-Excise Information System and Automation 4.0 as Indonesia rings the changes
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Sponsored by Lakshmikumaran & SridharanA multinational enterprise bearing the cost of an employee stock option plan granted to an Indian subsidiary creates several complexities, as explained by S Vasudevan, Harshit Khurana, and Sonali Bansal of Lakshmikumaran & Sridharan
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Sponsored by HLB ThailandStarting this year, Thailand’s Revenue Department has revised its approach to taxing foreign income received by tax residents. Paul Ashburn of HLB Thailand summarises the changes
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente suggest what documentation can demonstrate the reasonableness of the costs of an intra-group transaction, and the benefits for a subsidiary
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Sponsored by EY RomaniaAdrian Rus and Georgiana Bizdrigheanu of EY Romania explain the options for the country’s taxpayers in tackling double taxation and suggest how predictability and efficiency can be improved
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Sponsored by Deloitte LuxembourgBalazs Majoros of Deloitte Luxembourg provides an update on the transfer pricing landscape in the grand duchy against a backdrop of opposition to a draft bill and winds of change from the EU
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Sponsored by Ritch MuellerJuan José Paullada Eguirao and Gabriel Márquez García of Ritch Mueller explain the consequences of a foreign entity being deemed to have created a permanent establishment, and how to negate that risk
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Sponsored by Ritch MuellerThe interest of other FIBRAs in a potential acquisition of the Terrafina real estate investment trust highlights a lack of taxation guidance in such transactions, say Oscar López Velarde and Regina Albornoz of Ritch Mueller
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados discusses a highly questionable manoeuvre by the Brazilian Federal Revenue Service to boost tax collection, despite a decision by the Federal Supreme Court
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Sponsored by MachadoGabriel Caldiron Rezende of Machado Associados comments on a bill of law presented by the Brazilian Congress that outlines a recently created ‘sin tax’ on goods and services considered harmful to health or the environment
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Sponsored by MachadoJúlio Oliveira and Gabriel Caldiron Rezende of Machado Associados summarise the tax reform bill approved by the Brazilian Congress and believe it represents a leap towards a modern and international VAT standard, although some caution is necessary
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Sponsored by Ritch MuellerSantiago Llano Zapatero and Diego Guerrero Segura of Ritch Mueller note Mexico’s ‘remarkable’ digital transformation in invoicing, but issues in cross-border M&A transactions and a Supreme Court of Justice ruling suggest a tricky landscape
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Sponsored by Ritch MuellerJuan José Paullada Eguirao and David Guakil Raffoul of Ritch Mueller explain the computation and payment process of capital gains taxes derived from the sale of shares by non-Mexican residents
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Sponsored by Ritch MuellerOscar A López Velarde and Jesus Martín Corona González of Ritch Mueller explain the tax-related benefits of FIBRAs, a Mexican investment vehicle tailored to an evolving sector.
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Sponsored by Ritch MuellerSantiago Llano, Eric Palacios, and Alfredo Sampayo of Ritch Mueller report on an isolated but notable District Court precedent that has emerged in the dynamic landscape of Mexican labour and related taxation legislation.
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha, Murilo Jakuk Ferreira Lopes and Marina da Silva Fernandes of VRMA Advogados discuss the effects of Provisional Measure No. 1,152/22 regarding the deductibility of royalties from the corporate income tax assessment basis.
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha and Murilo Jakuk Ferreira Lopes of VRMA Advogados discuss a Brazilian tax reform approved by the Lower House of Representatives that includes the possibility of a VAT refund for lower-income taxpayers.
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Sponsored by MachadoMauri Bornia and Gabriel Caldiron Rezende of Machado Associados discuss the status of the tax reform bill approved by the Chamber of Deputies, to be analysed by the Senate during the second half of 2023.
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha and Marina da Silva Fernandes of VRMA Advogados discuss a Brazilian tax reform recently approved by the Lower House of Representatives, and the requirements of PEC 45/2019 to limit tax credits.
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Sponsored by VRMA AdvogadosPaulo Victor Vieira da Rocha and Murilo Jakuk of VRMA Advogados discuss the implications of Law No. 14,596/23 as Brazil attempts to align itself with international transfer pricing standards.
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Sponsored by Deloitte BrazilCarlos Ayub and Daniel Macedo of Deloitte Brazil examine the country’s latest legislative attempts to conform to international TP standards, with far-reaching implications for taxpayers.
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Sponsored by Yaron-Eldar Paller Schwartz & CoHenriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on two substantial new tax benefits designed to stimulate and preserve continued investment in technology companies
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Sponsored by Yaron-Eldar Paller Schwartz & CoHenriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv concludes the follow-up article on SAFE investments in Israel, outlining the relative certainty of walking the safe “green path”.
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Sponsored by Yaron-Eldar Paller Schwartz & CoIn the first of a two-part article, Henriette Fuchs of Yaron-Eldar, Paller, Schwartz & Co in Tel Aviv reports on Israel tax authorities’ acceptance of the SAFE for investment in innovative and tech companies.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the recent amount B consensus document and the associated compliance challenges
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt
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Sponsored by KPMG USMultinational companies face numerous year-end tasks but should not forget to file the treaty notifications that are required in certain US tax treaties, say senior tax practitioners from KPMG in the US
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the first published statistics on the International Compliance Assurance Programme and their implications for businesses looking to obtain tax certainty
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Sponsored by Vertex IncAgainst the backdrop of a domino effect in the introduction of mandatory e-invoicing among EU member states, Gunjan Tripathi of Vertex says businesses should future-proof themselves by proactively addressing the transition
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the tax certainty provisions of the Multilateral Convention for amount A and evaluate their utility for businesses