The appeal related to deductions claimed by the Singaporean telecoms company, which was advised by PwC, on a A$5.2 billion acquisition from 2002
Rob Clary observed that clients ‘have an expectation you can operate globally’ and that Baker McKenzie is well positioned to meet the demand
Experts from TP tech provider Aibidia also warned ITR that companies ignoring pillar two is a ‘huge issue’ and a ‘red flag’
Amount B is meant to increase simplicity and reduce uncertainty, but US TP specialists claim it may lead to controversy
Sponsored
Sponsored
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente analyse a significant addition to Italy’s case law on the application of transfer pricing regulations to interest-free loans between related parties -
Sponsored by DeloitteRalf Heussner, Anodri Suchdeve, and Fangying Xu of Deloitte examine the transfer pricing challenges arising from an increasing number of intra-bank funding arrangements as stricter capital requirements trigger the attention of regulators and tax authorities
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Sponsored by RSM IndonesiaIchwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explain the clarifications provided by the latest Indonesian transfer pricing regulation, but point out that uncertainty remains around several issues
Barbara Voskamp is bullish on hiring local talent to boost DLA Piper’s Singapore practice, and argues that ‘big four’ accountants suffer from a stifled creativity
But the US tax agency’s advice is consistent with OECD guidance and shouldn’t surprise anyone, other experts tell ITR
The report is aimed at helping 'low-capacity countries', the OECD has claimed
However, ICAP may not provide the legal certainty of an APA and tax authorities will have limited capacity, experts argue
The ‘big four’ firm hopes the new technology will make client service more efficient, while Pinsent Masons has appointed a new tax head in Dublin
There is definitely a role for ICAP in TP compliance for multinational enterprises, a TP leader told ITR
The letters don’t reflect final determinations that the taxpayer has underpaid US taxes, tax experts argue
RSM’s European leader tells ITR of surging pillar two client demands and capitalising on disillusioned talent from the ‘big four’
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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.
ITR invites tax firms, in-house teams, and tax professionals to make nominations for the 2024 ITR Tax Awards in the Americas, EMEA, and Asia-Pacific
The winners of the ITR Europe, Middle East, and Africa Tax Awards 2023 have been announced!
The winners of the ITR Asia-Pacific Tax Awards 2023 have been announced!
The winners of the ITR Americas Tax Awards have been announced for 2023!