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  • UK multinational and alcoholic drinks producer Diageo is the first company that will have to make an upfront tax payment to UK tax authority, HMRC, before it can challenge preliminary notices of assessment issued under the diverted profits tax (DPT) regime.
  • As the latest film in the DC franchise, Wonder Woman, premiers on the silver screen and fans get ready for the next instalment in November with Justice League, we are celebrating the wonder women and supermen of tax.
  • See who has done the tax work on this month’s biggest deals
  • The outcome of the Chevron appeal could set a precedent for future cases The Australian Tax Office (ATO) will go after other multinationals that it believes to be guilty of tax avoidance after winning a landmark transfer pricing case against global oil and energy company Chevron over shifting profits to the US.
  • Chinese policymakers have been closely following moves by various countries around the world to improve their investment attractiveness, including via tax policy, such as the US Trump Administration’s proposals on reducing the corporate tax rate to 15%. Khoonming Ho and Lewis Lu of KPMG China discuss the changes happening in China in response to the developments abroad.
  • During the OECD Ministerial Council Meeting, which is to be held in Paris in the week beginning June 5 2017, Mexico will finally make public its stance on Mandatory Binding Arbitration, write Alejandro Torres Rivero and Andrea Obregón Widmer of Chevez, Ruiz, Zamarripa y Cia.
  • Jim Fuller David Forst In Announcement 2017-3, 2017-15 I.R.B. 1, the US Internal Revenue Service (IRS) released its annual report on advance pricing agreements (APAs) for the 2016 calendar year. Fewer APAs were executed than in the prior year, and it took slightly more time to complete them. Of the 86 agreements executed in 2016, 37 were new APAs. This was a decrease from the 44 new APAs executed in 2015.
  • The Russian transfer pricing rules (TP rules) enacted in 2012 provide the opportunity for taxpayers to conclude both unilateral and bilateral advance pricing agreements (APAs). However, no bilateral APAs have been concluded until now.
  • Raoul Stocker Jonathan Belet On November 23 2016, the Federal Council adopted the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals (the Act) that aims to implement the country-by-country reporting (CbCR) standard in Switzerland as recommended by the OECD as part of the BEPS project. The Council of States passed the Act on March 16 2017 and the National Council will discuss the draft legislation in June 2017. If the Parliament (i.e. the Council of States and the National Council) approve the proposal and a referendum is not held, the Act should enter into force at the end of 2017.
  • Proposed changes to the Income Tax Act (Canada) included in the 2017 Federal Budget expand the relevant factors to be used in determining when de facto control of a corporation exists.