The judgment, which saw Denmark's Supreme Court rely on OECD TP guidance, sets aside more than 15 years of consistent administrative practice, experts have told ITR
In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present
France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
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Sponsored by HLB ThailandAmit Bhalla and Dean Rangel of HLB Thailand explore how rising global tariffs are disrupting transfer pricing arrangements, tested party selection, and benchmarking, with Thailand’s manufacturing sector facing increased pressure under shifting supply chains -
Sponsored by Deloitte LuxembourgDinko Dinev and Iva Gyurova of Deloitte Luxembourg analyse a landmark ruling on how economic substance plays a key role in determining whether interest-free loans from indirect shareholders constitute debt or equity for Luxembourg tax purposes
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Sponsored by Deloitte LuxembourgEdouard Authamayou of Deloitte Luxembourg examines a tribunal ruling on hidden contributions and profit distributions that highlights the importance of robust evidence supporting the arm’s-length principle in intragroup financing arrangements and interest rate waivers
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood
While pillar one is still alive, it will apply to a smaller group of companies, Brian Foley also told ITR
An Administrative Review Tribunal ruling last month in Australia v Alcoa represents a 'concerning trend' for the tax authority, one expert tells ITR
The plan aims to improve the efficiency, transparency, and effectiveness of direct tax administration in India
The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says
The MEGlobal Canada decision highlights taxpayers’ frustrations over split jurisdiction for TP assessments as well as a need for legislative reform, one expert tells ITR
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Opinion: Republicans risk more than they realise by opposing OECD
Conservative US politicians are building a narrative against the OECD’s two-pillar plan for international tax reform, but they have no serious alternative vision. -
Opinion: Biden could save pillar one, but there’s a catch
The OECD must pay attention to US politics because the next election could determine whether the country will make or break international tax reform. -
Opinion: Pillar one might already be doomed
The OECD’s plan to reform transfer pricing rules and international taxing rights still has to reckon with US uncertainty. -
ChatGPT is more opportunity than threat for tax leaders
Russell Gammon, chief solutions officer at Tax Systems, makes the positive case for AI in tax. -
ITR Summer Issue 2023: Editorial
ITR’s latest quarterly PDF is going live today, leading on the PwC Australia tax leaks scandal and its fallout for tax advisers.
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
Awards
ITR invites tax firms, in-house teams, and tax professionals to make nominations for the 2025 ITR Tax Awards in the Americas, EMEA, and Asia-Pacific
Awards
The firm also won regional awards for Pro Bono Firm of the Year and Tax Law Firm of the Year