BEPS and its influence on TP audit processes in Nigeria Victor Adegite of KPMG looks at how the Nigerian Federal Inland Revenue Service has incorporated BEPS Project action points into its transfer pricing audit processes.
International tax dispute resolution: Breaking the impasse Peter Nias, international tax specialist barrister at Pump Court Tax Chambers in London, analyses trends in international tax dispute resolution, looking at alternative dispute resolution methods and whether the OECD’s recent work in this area represents a missed opportunity.
BEPS: Everything asset managers need to know Sofia Stavridi, a Queen Mary University of London graduate now working in investment management tax services at a Big 4 firm in the UK, looks at the key BEPS actions impacting the asset management industry.
UK: Changes for fund managers and new anti-hybrid rules The UK draft Finance Bill 2016 was published on December 9 2015. Sandy Bhogal, head of tax at Mayer Brown in London, focuses on two topics of particular interest – new rules on taxation of performance-linked rewards for investment managers and new anti-hybrid rules arising out of the OECD’s BEPS Project.
The Cunningham column: Asian Budgets to focus on national over international tax The Budget season is about to start in Asia. Ralph Cunningham believes finance ministers are likely to prioritise local or regional concerns rather than get involved in any deep discussions about base erosion and profit shifting.
The Brockman brief: Audit and risk transparency: Why it matters ‘Transparency’ is the latest term of art that has emerged from the OECD’s Action Plan with respect to its base erosion and profit shifting (BEPS) initiatives. But the obvious question that has consciously been ignored in the public domain is: where are the matching transparencies regarding determination of tax risks and identification of substantive issues by tax authorities upon commencement and conduct of an audit?
The Global Tax 50 2015: The leaders creating an impact around the world Now in its fifth year, International Tax Review’s Global Tax 50 provides a rundown of the who’s who of the tax world. One way or another, these individuals and organisations have had an impact or influence on taxation that will be felt beyond the 12 month period covered by this list. Matthew Gilleard introduces the Global Tax 50 2015
Special features - February 2016 Read this month's special features for Canada, Mexico, US, Ireland and Intangibles
Why international tax treaty networks are an Animal Farm Fred Lo, vice president and global head of tax at Yanfeng Global Automotive Interiors, a joint venture between the automotive interiors businesses of Johnson Controls and Shanghai Motors, analyses recent tax treaty trends, focusing on mismatches in treaty terms and why some countries are more equal than others.
The new FIRPTA exemption for foreign pension funds Babak Nikravesh, partner at Hogan Lovells, unpicks the new FIRPTA exemption for foreign pension funds.
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.
Global Tax 50 2015: Will Morris Global tax policy director, GE; chairman, BIAC Tax and Fiscal Affairs Committee
Global Tax 50 2015: Mohammed Amine Baina Vice-chair, ad hoc group for the development of a multilateral instrument
Global Tax 50 2015: Elise Bean Head rapporteur, ICRICT; former staff director and chief counsel, US Senate Permanent Subcommittee on Investigations
Global Tax 50 2015: Monica Bhatia Head of secretariat, OECD Global Forum on Transparency and Exchange of Information for Tax Purposes
Global Tax 50 2015: Mauricio Cardenas Minister of finance and public credit, Colombia; chairman, Intergovernmental Group of Twenty Four on International Monetary Affairs and Development
Global Tax 50 2015: Allison Christians Associate professor, H Heward Stikeman chairwoman in the law of taxation at the McGill University faculty of law; ICRICT expert; blogger
Global Tax 50 2015: Marlies de Ruiter Head of division, Tax Treaty, Transfer Pricing and Financial Transactions, OECD CTPA
Global Tax 50 2015: Judith Freedman Professor of tax law, Oxford University; Director of legal research, Oxford University Centre for Business Taxation
Global Tax 50 2015: Kim Jacinto-Henares Commissioner, Philippines Bureau of Internal Revenue; vice-chairwoman, ad hoc group on BEPS Action 15
Global Tax 50 2015: Eva Joly MEP; vice-chairwoman, European Parliament special committee on tax rulings; ICRICT commissioner
Global Tax 50 2015: Alain Lamassoure MEP; chairman, European Parliament’s Special Committee on Tax Rulings
Global Tax 50 2015: Liao Tizhong Director general of international taxation, China State Administration of Taxation (SAT)
Global Tax 50 2015: Achim Pross Head of division, International Cooperation and Tax Administration, OECD CTPA
Global Tax 50 2015: Parthasarathi Shome Retired official; economist and government adviser; chairman, Shome Commission
Global Tax 50 2015: Robert Stack Deputy assistant secretary for international tax affairs, US Treasury
Global Tax 50 2015: Mike Williams Chairman, ad hoc group for the development of a multilateral instrument; director, business and international tax, UK Treasury
