ITR Search | International Tax Review

SC: dominant purpose of investment is irrelevant in determining whether expenditure is ‘in relation to’ exempt dividend income

Investor pressure drives corporate tax policy development

Investors are giving serious consideration to their targets’ corporate tax policies before agreeing on the deal, but there are a number of companies that still have no such policy in place.

Joseph Stanley-Smith, February 01 2019

India commits to anonymised tax return assessments in interim budget

India has confirmed its aim to move to anonymised tax return assessments (ATRAs) within two years, a measure which is dividing the tax community.

Joseph Stanley-Smith, February 01 2019

Tax directors explain the importance of data modelling

Businesses are increasingly using data modelling to more accurately determine their tax liabilities and prove their compliance to tax authorities amid the political pressures that are constantly changing the goal posts.

Danish Mehboob, February 01 2019

Akhilesh Ranjan Hitesh D Gajaria TPW large

APAs ‘an area of concern’ in India

Greater-than-expected numbers of advance pricing agreement (APA) applications are becoming a problem for the Indian system, with more resources needed to deal with increasingly complex applications, a senior government source has admitted.

Joseph Stanley-Smith, February 01 2019

Japanese companies fear the rise of the profit split method

As Japan moves towards a new transfer pricing (TP) regime, companies fear the increasing use of the profit split method could erode the arm’s-length principle (ALP).

Josh White, January 31 2019

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Does Portuguese tax law discriminate against EU pension funds?

Portuguese documentation requirements for tax exemption require EU pension funds to submit certifications that are difficult to obtain. Is this ultimately deterring pension funds from investing into Portugal?

January 31 2019

India joined 67 other countries in signing the Multilateral Instrument (MLI) in June 2017.

OECD announces countries' plans to revolutionise international tax system

The OECD has stunned the tax world by signalling countries’ willingness to consider radical steps to drag the global corporate tax system into the 21st century by addressing the challenges of the evolving world economy.

Alexander Hartley, January 30 2019

Now that China has data, what is it going do with it?

China has introduced a profit monitoring mechanism that taps into big data analysis to carry out risk assessments so that more targeted administrative action can be taken against large taxpayers.

January 29 2019

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

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