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  • TP Week embarks on a new series of features looking at up-and-coming jurisdictions for transfer pricing. This week, the Philippines is in the spotlight.
  • Has Ireland provided Apple with state aid or any other kind of special tax deal? Finance Minister Michael Noonan addressed parliament's questions.
  • Alfredo Sánchez Torrado and Eduardo García Ruiz examine the way in which investments are currently structured in Mexico via private equity funds, the application of treaty benefits by them, as well as how BEPS Action 6 may affect such application.
  • The boldest initiative in transfer pricing history entered the homestretch in October 2015 with the release of the OECD's final report on its base erosion and profit shifting (BEPS) project. The reverberations are being felt across North America, Europe, Asia and beyond.
  • The framework for analysing intercompany transactions involving intangibles is examined by Hendrik Blankenstein and Caterina Colling Russo at Tax Partner AG – Taxand Switzerland. Does the new DEMPE analysis benefit MNEs and tax authorities or simply confuse matters, resulting in an increase of intangibles-related disputes?
  • BEPS aims to prevent aggressive profit-shifting strategies to better align transfer pricing outcomes with value creation. In this paper, Dale Hill, a partner at Gowling WLG, examines BEPS’s application to the transfer pricing aspects of intangibles and the impact on tax-motivated IP migration strategies.
  • The Internal Revenue Service appears to be strengthening its stand on aggregating transactions and applying economic substance rationales to override related-party contracts. David Forst and Larissa Neumann of Fenwick & West discuss US developments including the IRS and Treasury Department-issued 482 Temporary Regulations.
  • Much lies beneath the surface of BEPS. How will BEPS affect Korean multinationals and what do MNEs need to learn? Tae Hyung Kim, partner and senior transfer pricing economist at Deloitte Korea, explains exactly what multinationals must consider and what they should fear.
  • The Supreme Court in Delhi has accepted an appeal from the Income Tax Department (ITAT) against a Bombay high court order, which rejected the ITAT’s transfer pricing adjustment for the sale of one of its call centres in 2007.
  • The Delhi Supreme Court will hear the Income Tax Department's (ITAT) appeal against the Bombay High Court’s rejection of an ITAT transfer pricing adjustment against Vodafone.