Tax watch: The decade of digital surveillance More electronic compliance, integrated software, data exchanges and an anticipated overhaul of the international tax rules will dominate the next decade. This all amounts to one message: Governments will know your every move. Are you ready?
Market insight In this month's round-up of changes, we feature new partners joining firms across the world, including Blake, Cassels & Graydon, King & Spalding, Baker McKenzie, Vertex and many more.
Taxpayers moving away from the Big Four to law firms for advice The EU’s mandatory disclosure regime (DAC6) and budget constraints are leading some tax executives to reassess how they use the Big Four accountancy firms for advice, with some preferring the protection of legal privilege offered by law firms.
Tax lens into the future The OECD’s pillar one and pillar two tax initiatives represent the opening act into the future international tax landscape, writes Keith Brockman.
Case study: Using an ‘APA model’ to gain tax certainty One head of tax at a European consumer goods company talks to ITR about their experience of negotiating a bilateral advance pricing agreement (APA) to safeguard transfer pricing arrangements.
Joint audits: The German experience Michael Braun, Thomas Eisgruber, Stefan Greil and Stephan Schmitz of the German tax administration discuss their experience with joint audits and why cooperation matters.
OECD Global Forum outlines what’s next in the tax transparency revolution The OECD’s Global Forum plays a vital part in achieving international tax transparency. Here, Global Forum Head Zayda Manatta, Radhanath Housden, head of the AEOI Unit, and Adrian Wardzynski, policy advisor, outline the successes of the past decade and what to expect in the next 10 years.
A practical guide for grading an MNE’s transfer pricing function See how your company scores on TP Consultant Richard Goldberg’s 10-minute MNE transfer pricing function quality assessment test. Then, consider enhancing your MNE’s transfer pricing function in light of any identified risks.
Tax functions must break through ‘midlife crisis’ for a better future Marc Mokrab, group tax director at Technicolor, discusses the three fundamental trends that will influence how tax departments transition from the ‘old world’ into a new era of taxation, technology and responsibility.
India’s policies to tackle tax evasion create MNE compliance woes Manish Agarwal, head of tax at Sasken Technologies, explains how the Indian government’s latest attempts to tackle GST tax avoidance and evasion are creating compliance and administrative burdens for large businesses, which risks discouraging compliance.
How to prepare for Brazil’s tax reform proposals in 2020 Ivan Tiburcio, tax accountant at Kerry Group, explains how a Brazilian company should monitor and prepare for Brazil’s tax reform proposals and anticipated transfer pricing changes.
Transfer pricing cases to watch in 2020 Taxpayers must prepare for an increasing number of difficult questions from the tax authorities over the coming decade. ITR reviews a few of the biggest upcoming TP cases for tax professionals to keep an eye on in 2020.
Reviewing Wayfair’s Impact: A year and a half later The Wayfair case changed the way US states impose sales tax and many businesses have been reeling from the impact of the decision ever since. Professor Wally Hellerstein explores the case and its relevance in 2020.
TP aspects of intangibles: How deep should DEMPE be? Philippe Paumier, founder of VECTOR TP, addresses some of the common challenges MNEs face on DEMPE analysis and how the enterprise risk management, governance compliance and risk frameworks are relevant.
The ‘Power of With’: Combining humans and machines to transform tax New technologies are increasingly helping modernise the tax function. Deloitte’s Amanda Hale, Emily VanVleet, Jeff Butt and Taj Hollis outline how future tax leaders will be able to reap benefits from the digital transformation.
Challenges of the MLI: Taxpayers caught in the chaos Are countries implementing the Multilateral Instrument for the sake of it, or will it bring about real change? Karnik Gulati questions the real consequences of the MLI and suggests how companies should prepare.
Selecting the ideal European HQ location The location of a multinational enterprise’s (MNE) headquarter is a fundamental issue for any large company operating in Europe today. Eurofiscus TP consultants Arthur Pleijsier and Sander Pleijsier assess the best locations.
IR35: Preparing for the UK’s off-payroll anti-tax avoidance rules by April 2020 Tax departments need to work closely with their HR teams to ensure compliance with the UK’s IR35 rules. Mala Kapacee, director of London Tax Network, explains how companies should get ready for the amendments to the anti-avoidance measure.
Will the 2020s be the decade of ‘fair’ tax? Greater tax disclosures with the facts behind the numbers can lead to a better understanding of an MNE’s tax strategy, writes Giles Parsons. However, achieving the ‘fair’ tax balance is not that simple.
Can a robot write this? The ITR team regularly speaks to tax professionals, who help to inform our decisions on articles.
Tax Relief Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.
Argentina: Argentina introduces major tax reform Ignacio Rodríguez and Juan Manuel Magadan of PwC Argentina outline the impact of Argentina’s significant tax reform and analyse key considerations for taxpayers.
Australia: Tax round-up Jock McCormack of DLA Piper summarises tax-related developments which rounded off 2019 in Australia.
Chile: Digital services tax, technological assessments and data protection Sandra Benedetto and Jonatan Israel of PwC Chile explore the continuing clash between technological innovation, data protection and legal regulation in Chile.
China: Tax legislation progress and a new foreign investment law Lewis Lu of KPMG summarises the two most important tax developments in China at the turn of the decade, as the economy continues to open to inbound and outbound investment.
Hong Kong: New ruling clarifies taxing termination payments in Hong Kong Lewis Lu and John Timpany of KPMG analyse a significant decision by the CFA which provides further clarity on the reach of salaries tax.
India: The interplay of India’s new insolvency code with income tax law Mehul Bheda and Kushal Parikh of Dhruva Advisors examine how the financial landscape may evolve in India under the new insolvency regime.
Indonesia: January 2020 tax round-up Dewa Nugraha and Dwipa Abimanyu Dewantara of GNV Consulting Services summarise tax-related developments from January 2020 in Indonesia.
Greece: Greece introduces an attractive tax status for foreign high net-worth individuals Manos Tountas of EY Greece examines the new ambitious tax law which could help bring a new wave of wealthy entrepreneurs into the peninsula.
Italy: Italian entry tax in merger operations Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners explain the latest clarifications on entry tax associated with mergers by incorporation in Italy.
Luxembourg: Tax impact of the global IBOR transition Ralf Heussner of Deloitte Luxembourg explores the key challenges for tax departments related to the IBOR transition.
New Zealand: Proposed changes to foreign investment consent rules to include tax measures Brendan Brown and Alex Ladyman of Russell McVeagh assess the impact of the tax measures likely to feature in the Government's proposed changes to the Overseas Investment Act.
Mexico: Mandatory disclosure requirements to be needed for certain tax structures Ricardo Gonzales Orta and Mauricio Martínez D´Meza Violante of Deloitte Mexico discuss the SAT’s intended move towards a more thorough and transparent reporting model.
Poland: Poland prepares for new TP-R reporting Magdalena Marciniak and Magdalena Dymkowska of MDDP outline how the new TP-R form will make positive changes to the art of tax reporting in Poland.
Romania: Casting a glimpse to the future of the VAT system in the EU and Romania Alex Milcev of EY Romania provides insight into how the proposed recommendations for improving the VAT system and reducing VAT evasion may materialise.
Switzerland: Swiss VAT changes lead to simplified reporting requirements for foreign businesses Romy Mueller and Jan Widmer of Deloitte Switzerland explain recent administrative changes which seek to clarify tax liability for foreign investors.
US Outbound: CSA netting for BEAT should still work despite Treasury’s reticence Mark Martin and Thomas Bettge of KPMG US explain what the final BEAT regulations had in store for the much-discussed netting provisions.
US Inbound: Understanding the new BEAT regulations Jim Fuller and David Forst of Fenwick & West explain the most significant provisions from the new regulations on base erosion and anti-abuse tax.
