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  • Articles 56 EC to 58 EC – Free movement of capital – Taxation of dividends – Concession granted to a fiscal investment enterprise on account of tax deducted at source by another state from dividends received by that enterprise – Restriction of that concession to the amount that a shareholder resident in the member state of establishment of that enterprise who has made an investment without such an enterprise acting as intermediary could have had credited to income tax on the basis of a convention for the prevention of double taxation – Restriction of that concession by reference to the shares of non-resident shareholders in the capital of that enterprise.
  • The complexity and instability of the UK tax system hurts businesses who crave stability and gives companies a huge incentive to fiddle the system and to leave Britain altogether, says Nick Clegg, leader of the country's Liberal Democrat party.
  • NERA Economic Consulting, an independent international firm of economists, has appointed a veteran of Deloitte and Andersen as head of its UK transfer pricing group
  • Former Cadbury Schweppes and Andersen tax man is specialist in APAs
  • Deanna Flores has joined KPMG's Washington National Tax financial institutions and products group as a principal. Flores will work in the firm's San Diego office. She joined from Vanguard, an investment management company, where she was the company's first general tax counsel.
  • Responses to consultation paper support wide use of transactional profits methodologies
  • Juan Carlos Ferreiro, of TP Week correspondent PricewaterhouseCoopers in Argentina, comments on the computerisation of transfer pricing information
  • Polish authorities step up scrutiny of related party documents in transfer pricing sweep
  • Brazil, South Africa and India propose joint approach on transfer pricing
  • Richard Sherman has joined Alvarez & Marsal Taxand in the firm's Chicago office. Formerly of Ernst & Young, Sherman is a senior director in the transaction tax practice and focuses on advising on the tax aspects of M&A, including reorganisations, acquisition and disposition planning. He has also advised private equity clients on domestic and cross-border transactions involving tax due diligence, tax structuring and financial modelling.