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  • Under the Investment Promotion Act (BOI Act), the Board of Investment of Thailand can grant certain privileges including the exemption of duty, tax holidays, land ownership, and so on to an eligible future business or project. As one of the privileges, a BOI promoted company can utilise its loss carried forward for five years after the expiration of its tax holidays (maximum eight years). The problem is when the promoted company also has more than one BOI business or project. The BOI has advised the promoted companies that the loss on any BOI business or project should be computed on the BOI project basis. It is not necessary to consolidate the losses with the profits of all the BOI projects of one company.
  • Vicente Bootello There have been some new developments recently in the case law relating to the right to deduct the remuneration paid to members of the board of directors for corporate income tax purposes.
  • Roberto del Toro David Cuéllar The Mexican and British authorities signed a new protocol to the Mexico – UK tax treaty on April 23 2009. There are still several pending requirements to be fulfilled in order for it to be approved and subsequently enter into force.
  • Vu Tran and Alexander Gurevich of PricewaterhouseCoopers in the US discuss how the change from US GAAP to IFRS will affect cost sharing arrangements
  • Differences in the application and enforcement of customs and transfer pricing rules causes significant problems for taxpayers according to advisers.
  • We are a Chinese Sanlaiyibu-type export processing trade company. As we do not take title to any materials, are we subject to China TP rules and required to prepare transfer pricing documentation?
  • The Australian Tax Office has been given more government money to tackle aggressive schemes as the onslaught on transfer pricing uses continues in the country.
  • Freshfields Bruckhaus Deringer gives Danny Beeton the nod as the firm’s head of transfer pricing economics.
  • KPMG in the US has appointed Chris Housman as partner in the firm's international corporate services group.
  • Australia's government has signed a new double tax agreement with New Zealand which will benefit taxpayers from both jurisdictions.