ITR Search | International Tax Review

Tax incentives in Georgia for IT corporations

Georgia’s tax legislation offers a number of high value incentives for IT corporations operating in the country and offering IT services to foreign customers, writes Gela Barshovi, chief auditor of transfer pricing at the Georgia Revenue Service.

September 03 2018

Poland’s exit tax could raise business costs

Poland’s proposals to introduce an exit tax may unintentionally raise costs for some businesses that regularly operate across borders, warn practitioners.

Josh White, August 31 2018

IFA President Murray Clayson on what to expect in Seoul

IFA President Murray Clayson predicts a greater international appetite for a digital profits-based tax and an extended PE concept as he talks to International Tax Review about the 72nd Congress in Seoul.

Josh White, August 31 2018

The case highlights a new challenge of attributing intangible-related profits, namely identifying the owners of intangibles.

TP in China: SAT tapping into the tax big data paradise

Transfer pricing continues to be one of the Chinese State Administration of Taxation’s key focus areas, write Cheng Chi, Rafael Triginelli Miraglia and Choon Beng Teoh of KPMG. New policies and methodologies are being examined post-BEPS to strengthen the SAT’s monitoring of MNEs’ TP.

August 30 2018

McDermott Will & Emery hires three new state and local tax lawyers

McDermott Will & Emery has responded to the increasingly complex US tax environment by hiring three state and local tax lawyers.

Joe Stanley-Smith, August 29 2018

Coca-Cola faces big US tax bill if Medtronic loses dispute

Coca-Cola’s profit split method may result in the soft drinks giant having to pay a $3.3 billion tax bill if the US Tax Court decides to reverse its earlier decision on the Medtronic case.

Josh White, August 29 2018

Asia Pacific – a harmonious interplay between transfer pricing and customs valuation?

The rise of integrated supply chains, complex organisational structures and inter-company transactions, means the harmonious interplay between customs valuation and transfer pricing has never been more important, writes Leonie Ferretter of KPMG. However, across the Asia Pacific region, we continue to see disparity in how TP is treated from a customs perspective.

August 28 2018

Editorial

Welcome to International Tax Review's guide to intangible assets, published in association with Deloitte. In today's digital revolution, intangible assets are as central to the business function as steam-powered machines were during Industrial Revolution.

August 28 2018

Brand value, brand equity, and brand IP

Brands are complex intangible assets. As explained by Tim Heberden and Cam Smith of Deloitte, robust valuations and royalty opinions should incorporate analysis of the legal rights underpinning the brand, together with the associated reputational stock that drives purchase behaviour.

August 28 2018

The hypothetical arm’s-length test: Germany’s way of calculating the ALP for IP

The German approach to determining the arm’s-length price for intangibles/intellectual property (IP) is based on the relevant German tax code and related administrative guidance, explain Richard Schmidtke, Bjorn Heidecke and Oskar Glaser of Deloitte. If other methods are used to determine the arm’s-length price for IP, this may result in non-compliance in Germany.

August 28 2018

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