ITR Search | International Tax Review

Italy: Italy is reviewing the criteria to identify tax havens

Giuliano Foglia

January 27 2015

Analysing the Brazilian tax authorities’ approach to royalty payments

A series of articles which will address the issues taxpayers face with the Brazilian tax authorities when dealing with royalty payments.

January 27 2015

U-turn in CBSA’s stance on TP adjustments for customs purposes is welcome news for importers

The Canada Border Services Agency (CBSA) recently changed its policy on transfer pricing adjustments for customs purposes. The new policy allows eligible importers to seek refunds of custom duties where transfer prices are adjusted downward.

Sophie Harding, January 27 2015

Kirkland & Ellis hires Beinus for LA office

Michael Beinus has joined the Los Angeles office of Kirkland & Ellis as a tax partner, moving from Skadden, Arps, Slate, Meagher & Flom.

Joe Stanley-Smith, January 26 2015

Scardoni joins DLA Piper’s Luxembourg office

Geoffrey Scardoni has been announced as a new tax partner in DLA Piper’s Luxembourg office with two associates, Magdalena Mozdzierz and Kim Ngo, joining him.

Joe Stanley-Smith, January 26 2015

Taxpayers on whether TP service providers are meeting industry needs

As transfer pricing (TP) becomes more demanding for multinational companies their need for TP service providers with industry experience increases.

Sophie Ashley, January 26 2015

Business speaks out on preventing treaty abuse

Businesses have made their feelings clear about the OECD’s work on preventing treaty abuse, which is a sub-section of the organisation’s work on base erosion and profit shifting (BEPS).

Sophie Ashley, January 26 2015

BEPS Action 10 feedback shows cost pool remains a contentious issue

Public comments on BEPS Action 10 welcome the OECD’s simplified approach to dealing with low value-adding intra-group services and generally support the proposed profit mark-up range. However, feedback has stressed the need for clarification over more valuable services and single cost pool allocation has been deemed impractical.

Sophie Harding, January 26 2015

Why it is crucial the OECD’s work on dispute resolution succeeds in the eyes of business

The chairman of BIAC’s tax committee, Will Morris, made an address to the OECD’s consultation on dispute resolution last week and said success on the dispute resolution action item is crucial to the overall success of the BEPS project as a whole.

January 26 2015

Portugal unveils new collective investment undertakings tax regime

Portugal’s new regime for the taxation of UCIs (undertakings for collective investments) aims to increase the attractiveness of using the securities and benefit in particular foreign investors. Only the future will tell if the purposes of these changes have in fact been achieved.

January 23 2015

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