LEAD ARTICLE
LEAD ARTICLE
Sponsored
Sponsored by
Gatti Pavesi Bianchi Ludovici
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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 DLA Piper AustraliaThe discontinuation of a proposed measure to deny deductions for certain payments relating to intangibles is among several taxation updates in Australia’s federal budget, as summarised by senior tax practitioners from DLA Piper Australia
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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 Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici focus on how the simplified and streamlined approach set out in the OECD’s Pillar One – Amount B report enhances tax certainty
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Sponsored by Morais Leitão, Galvão Teles, Soares da Silva & AssociadosTaxation when companies acquire shares in entities that hold real estate can be a fiendishly complicated issue. Ricardo Seabra Moura of Morais Leitão, Galvão Teles, Soares da Silva & Associados summarises the regulations and interpretations
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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 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 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 analyse the 2022 mutual agreement procedure statistics for the US and discuss their significance for businesses
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the IRS Appeals process, including recent developments that affect how Appeals functions
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the US TP penalty regime and a recent shift towards more aggressive penalty enforcement by the IRS.
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Sponsored by Deloitte GermanyClaudia Lauten and Janis Sussick of Deloitte discuss how the resurgence of large-scale government subsidies can impact the tax and TP approaches of global multinational enterprises in the industrial products and construction (IP&C) sector.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss IRS alternative dispute resolution (ADR) and prevention programmes and how their underutilisation impedes effective tax administration.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the recently announced IRS procedures for reviewing advance pricing agreement (APA) requests and what these procedures mean for taxpayers.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the IRS’s APA statistics for 2022, and the state of the IRS APA programme.
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss enforcement-related proposals in US Treasury’s latest Green Book, and how they would change the tax compliance and enforcement landscape for large businesses.
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Sponsored by Vertex IncVertex’s Niall Kiernan highlights four potential game-changers for marketplaces that want to get a grip of their tax calculation.
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Sponsored by Vertex IncLarry Mellon, tax director in the Chief Tax Office at Vertex Inc., encourages businesses looking to trade across the pond to implement a US sales tax strategy to prepare for the complexities.
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Sponsored by KPMG GlobalBernard van Gerrevink and Hilde Atsma of KPMG Meijburg & Co and Jenny Wong of KPMG Australia explain why tax transparency is set to become an integral part of ESG disclosures.
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Sponsored by DeloitteRather than simplifying and standardising international tax, the OECD BEPS recommendations have led to a complex landscape. Vrajesh Dutia and Eric Lesprit of Deloitte analyse the application of the guidance across several high-profile jurisdictions.
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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