Sponsored

Subrogation to the tax rights and obligations in mergers, spinoffs and asset contributions, remains unaltered.

Without much fanfare, a tax reform in Chile in December 2017 broadened the rules on the parties considered related for transfer pricing purposes, write Roberto Carlos Rivas and Gregorio Martínez of PwC.

After launching the Zelotes operation, the discussion on the restructuring of the Administrative Tax Appeals Council (CARF) was intensified. In relation to this, there are at least six bills pending before the Brazilian Congress, write João Marcos Colussi and Gabriel Mendes Gonçalves Issa of Mattos Filho.

The issue of whether a waiver of loans results in taxable income for the borrower has been a controversial one in India.

Following on from the annual meeting of China's Parliament, the National People's Congress (NPC), in early March, the Chinese government has been implementing a string of tax reform measures, the most recent of which was the VAT rate reductions.

Mark Martin and Cameron Taheri of KPMG take a closer look at the IRS's APA statistics for 2017.

In the first of a series on transfer pricing technical challenges and solutions to changing economic and regulatory environments for global multinationals, this article focuses on the remuneration of top management functions in the inter-company context.

Over the years, the Chilean IRS has issued a number of rulings on how to apply Article 12 (royalties) of double tax agreements (DTAs). These have been particularly in regard to the taxation over payments made from Chile to overseas countries for distribution rights, and their characterisation as intangible property.

The New Zealand government has announced a non-refundable tax credit of 12.5% of eligible research and development (R&D) expenditure (R&D credit), from April 2019.