ITR Search | International Tax Review

Americas Tax Awards 2018: Enter now

The submissions period for this year’s Americas Tax Awards is open. Private-practice firms, in-house companies and individual tax professionals can win.

Anjana Haines, April 30 2018

US tax reform: the pitfalls of Section 965 on foreign earnings

The Internal Revenue Service (IRS) has left many questions unanswered about the impact of Section 965 on foreign earnings with Notice 2018-26.

Josh White, April 30 2018

Companies look to new APA regime for interest deduction loophole

Polish advisers expect to see a huge wave of simplified advance pricing agreement (APA) requests in the coming months. Changes to the Corporate Income Tax Act prohibit tax deductibility of certain costs acquired from related entities, but this does not apply if taxpayers obtain APAs.

Lena Angvik, April 30 2018

Americas Tax Awards 2018: Enter now

The submissions period for this year’s Americas Tax Awards is open. Private-practice firms, in-house companies and individual tax professionals can win.

Anjana Haines, April 27 2018

EU takes aim at letterbox company tax avoidance

Companies are disheartened to learn that they could face yet more anti-avoidance legislation if the EU enacts a proposal for a company law which would prevent cross-border conversions for the purpose of avoiding tax through artificial structures.

Lena Angvik, April 27 2018

New circular on German treaty shopping rules following ECJ dispute

Following the ECJ ruling in the Deister Holding and Juhler Holding joined cases, the German financial authorities have published a circular invalidating a section of the German Income Tax Act effective from 2007-2011, and softening the provisions applicable today.

Joe Stanley-Smith, April 27 2018

Foreign investors fear Brazilian courts' inconsistency in tax matters

Brazil has a very complex tax system that lacks predictability in its enforcement. Alessandra Gomensoro and Ricardo Cosentino of Mattos Filho, Veiga Filho, Marrey Jr e Quiroga Advogadosdiscuss why this repels foreign investors who, not understanding and foreseeing its rules, are afraid of investing because of the constant legislative alterations and changing precedents.

April 27 2018

Yoon & Yang hires former judge as tax partner

Yoon & Yang has appointed Jeongsu Park to partner at its Seoul-based tax practice. Park served as a judge for more than 17 years.

Josh White, April 27 2018

Will the EU raise the bar for protecting whistleblowers?

LuxLeaks whistleblower Antoine Deltour has told International Tax Review why he thinks the European Commission’s proposal to strengthen protections for whistleblowers across the EU may not get enacted.

Josh White, April 27 2018

Digital tax proposals spur arm’s-length principle debate

The European Commission’s proposals for taxation of the digital economy has prompted new discussions on whether the arm’s-length principle has a future or if a move towards formulary apportionment could be an option.

Lena Angvik, April 25 2018

Search results for