Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
TP is a growing priority for West and Central African tax authorities, writes Winnie Maliko, but enforcement remains inconsistent, and data limitations persist
Increasingly, clients are looking for different advisers to the established players, Ryan’s president for European and Asia Pacific operations tells ITR
The tariffs are disrupting global supply chains and creating a lot of uncertainty, tax expert Miguel Medeiros told ITR’s European Transfer Pricing Forum
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Sponsored by Deloitte LuxembourgDinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied -
Sponsored by Crowe Valente/Valente Associati GEB PartnersThe Italian framework for tax certainty has been reinforced through advance pricing agreements, mutual agreement procedures, and other dispute resolution tools, explain Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente
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MAP cases keep increasing, and cases closed aren’t keeping pace with the number started, the OECD’s Sriram Govind also told an ITR summit
ITR spoke to two US TP experts about the long-running dispute, with one arguing that the case highlights ‘weaknesses’ with the comparable uncontrolled transaction method
US President Donald Trump’s tariffs may get thrown out by courts in the future and taxpayers should already be planning for that possibility, BDO’s Dustin Stamper tells ITR
The firm has appointed Deloitte’s former tax leader for Thailand to lead the new operation, which builds on considerable Asian investment in recent months
The firm is hunting for a senior TP manager in its quest to build a full-service practice in Indonesia, A&M Tax’s Jakarta head Jaap Zwaan tells ITR
PepsiCo was represented by PwC, while the ATO was advised by MinterEllison, an Australian-headquartered law firm
Tax auditors themselves had not been aware of the new TP ‘transaction matrix’ requirements, ITR hears as five German partners share their client experiences
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
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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
The ‘big four’ firm scooped over 60 honours at a lively ceremony held at The Londoner hotel, including both EMEA and APAC Tax Advisory Firm of the Year
Awards
ITR is delighted to reveal the first shortlisted nominees for the Middle East Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Americas Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards