ITR Search | International Tax Review

Country ceiling principle offers TP alternative for developing countries

The lack of comparables remains one of the biggest challenges for transfer pricing (TP) professionals, especially in low capacity countries. Gela Barshovi explains how the country ceiling principle may help companies and tax administrations to determine risks, benchmarks and establish comparables.

January 29 2019

Nuances embedded in Russia’s participation exemption

Russian legal entities that make capital gains from the sale of shares are eligible for a 0% tax rate, yet the criteria for satisfying this arrangement may not always be so simple.

January 29 2019

Cryptoassets: UK and US approach transactions in similar manner

The UK’s tax authority, HM Revenue and Customs (HMRC), has recently published updated guidance on the tax treatment of cryptoassets. Kate Habershon, Neil McKnight and Nelson Yates II of Morgan, Lewis & Bockius examine the guidance and how it compares to the US’s perspective.

January 29 2019

Baker Botts hires Jon Feldhammer as partner in San Francisco

Jon Feldhammer has joined Baker Botts’s San Francisco office as a tax litigation partner.

January 28 2019

Who controls the digital tax debate?

Businesses shouldn’t think about compliance with EU digital tax proposals, but instead influence the conversation and ensure governments aren’t hitting them by accident, say tax executives, advisors and lobby groups.

Alexander Hartley, January 28 2019

The dangers of tax 'over-tooling'

In-house tax teams are implementing tailored software solutions due to the low cost of technology, but should beware of ‘over-tooling’ and employ a coherent purchasing strategy, writes Danish Mehboob.

Danish Mehboob, January 28 2019

A practical guide for operational transfer pricing excellence

A well-constructed and executed global operational transfer pricing (OTP) framework is essential to properly manage financial statements, taxes and reputational risk for multinational enterprises (MNEs), writes Richard Goldberg, former tax director at Mitsubishi Financial Group.

Richard Goldberg, January 28 2019

UK’s profit diversion compliance facility shows emphasis on TP

A new ‘profit diversion compliance facility’ (PDCF) announced by the UK tax authority aims to encourage companies to bring their transfer pricing (TP) arrangements in line with HMRC’s interpretation of the arm’s-length principle, writes Ben Regan, transfer pricing partner at EY.

Joseph Stanley-Smith, January 28 2019

Tax directors should change how they think about VAT in the GCC

Businesses are at risk of being caught unaware if they ignore the continuous amendments to VAT regimes across the Gulf Cooperation Council (GCC) member states, tax heads warn.

Alexander Hartley, January 28 2019

REITs on the rise under Trump’s tax cuts

Advisors and fund managers expect more qualified opportunity funds (QOFs) to be organised as real estate investment trusts (REITs) to maintain key US tax benefits under the TCJA's qualified opportunity zone (QOZ) programme and avoid locking in investments.

Danish Mehboob, January 28 2019

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