The case shows that legal relationships between parties bear significance and should be given sufficient weight in TP analyses, one local adviser says
While pillar one is still alive, it will apply to a smaller group of companies, Brian Foley also told ITR
While GCCs drive efficiency for multinationals, they also present a host of TP risks that should be considered carefully
Following a $28 million funding round, Aibidia wants to ‘double down’ on the US market via partnerships with the ‘big four’, the Finnish TP tech provider’s CEO tells ITR
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Sponsored by DeloitteVanesa Lanciotti of Deloitte Chile explores how recent reforms – including new advance pricing agreement rules, enhanced audit priorities, and disclosure requirements – are reshaping transfer pricing practice and compliance for multinationals operating in Chile -
Sponsored by DeloitteSenior Deloitte tax practitioners examine Mexico’s evolving approach to the OECD’s amount B and summarise the transfer pricing landscape in Guatemala, Panama, Honduras, and Costa Rica
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Sponsored by DeloitteSenior Deloitte tax practitioners report that transfer pricing audits are homing in on intercompany services in Argentina, Uruguay, Colombia, Peru, Ecuador, and Venezuela, and emphasise the need for early taxpayer preparation
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
The ruling is ‘well-structured’ in its references to the OECD TP guidelines, one expert says, while another argues it overlooks key technical issues
India also brokered its first-ever multilateral APA last year, the Central Board of Taxes announced
Looking at transfer pricing simplification is “obviously helpful”, but it should be done in line with current standards, a senior government figure reportedly said
The UK Government’s plans to close the tax gap via increased HM Revenue and Customs investment have failed to impress local tax advisers
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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 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
Awards
The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2024 Americas Tax Awards