This content is from: Sponsored Chile aligns with OECD three-tiered transfer pricing documentation approach Roberto Carlos Rivas and Carolina Céspedes Lacombe of PwC take a look at the practical implications of the latest transfer pricing affidavits in Chile. By Carolina Céspedes Lacombe & PwC Chile & Roberto Carlos Rivas September 30 2020
This content is from: Singapore Digital tax and DST concerns dominate ITR’s Asia Tax Forum 2020 Indirect tax and transfer pricing dominated this year’s ITR Asia Tax Forum as double taxation risks from digital services taxes (DSTs) continue to rise and many prepare for the OECD’s final digital tax proposals due i... By Anjana Haines September 30 2020
This content is from: Sponsored Turning the tax tables – ITR’s Mexico Special Focus launched As Mexico travels through a period of tax reform, ITR has partnered with leading advisors to give you the key takeaways for the upcoming year and decade ahead. By Prin Shasiharan September 30 2020
This content is from: Global World TP 2021 is live: A guide to the world's leading transfer pricing firms World TP is proud to announce the 2021 edition of the comprehensive guide to the world’s leading transfer pricing firms. By Jon Moore September 30 2020
This content is from: European Union Businesses need to engage more with EU leaders, says policy advisor Companies need to engage more with the EU over its digital tax plans, according to one EU policy advisor speaking at ITR’s Digital Economy Summit. By Josh White September 30 2020
This content is from: Transfer Pricing Serious problems emerging from OECD digital tax solution, say taxpayers The risks of the OECD’s solution on how to tax the digital economy falling short are growing and tax professionals are warning that the consequences will leave long-term scars. By Josh White September 29 2020
This content is from: Sponsored Transfer pricing remains crucial as IRS CAP programme opens for 2021 Mark Martin and Thomas Bettge of KPMG in the US note the opening of applications for the IRS’ CAP programme’s 2021 year, and reflect on how the programme’s approach to transfer pricing has shifted in recent years. By KPMG US & Mark Martin & Thomas Bettge September 29 2020
This content is from: Sponsored Assessing the main transfer pricing challenges for Polish taxpayers in 2020 Magdalena Marciniak and Marta Klepacz of MDDP discuss the key considerations that Polish businesses must look out for as they complete their transfer pricing obligations. By Magdalena Marciniak & Marta Klepacz & MDDP September 29 2020
This content is from: Sponsored How to share manufacturing network losses in the face of COVID-19 Yves Hervé and Philip de Homont of NERA Economic Consulting explain how multinationals can plan to mitigate losses faced in their manufacturing transfer pricing model. By Nera & Philip de Homont & Yves Hervé September 28 2020
This content is from: Global World Tax 2021 is live: A guide to the world's leading tax firms World Tax is proud to announce the 2021 edition of the comprehensive guide to the world’s leading tax firms. By Jon Moore September 28 2020
This content is from: Global This week in tax: EU appeals Apple state aid case This week the European Commission confirmed it will appeal the Apple state aid case, while new OECD pillar one and pillar two blueprints were leaked ahead of the October meetings. By Anjana Haines September 25 2020
This content is from: China Webinar: Regional value chain re-imagination ITR and KPMG China will host a webinar on October 21 to discuss how multinationals could improve operational and tax efficiency via value chain re-imagination. By KPMG China & Patrick Lu & Prin Shasiharan September 25 2020
This content is from: Global Americas Tax Awards 2020: The winners The winners of the ITR Americas Tax Awards have been announced through a webinar presentation. By Prin Shasiharan September 24 2020
This content is from: Sponsored Building the tax controversy environment in Africa, Southeast Asia and the Middle East Fred Omondi, Carlo Llanes Navarro, Anil Kumar Gupta, Lenny Saputra and Rabia Gandapur look into how developing economies across the world are embracing increasingly complex transfer pricing framework. By Anil Kumar Gupta & Carlo Llanes Navarro & Deloitte Transfer Pricing Global & Fred Omondi & Lenny Saputra & Rabia Gandapur September 24 2020
This content is from: Sponsored The challenges of applying the 2017 OECD guidelines to pre-2017 years Jari Ahonen and Juan Ignacio de Molina discuss global examples and assess the practical impact of retroactively applying the OECD Transfer Pricing Guidelines. By Deloitte Transfer Pricing Global & Jari Ahonen & Juan Ignacio de Molina September 24 2020
This content is from: Sponsored Financial transactions: A complex landscape for taxpayers and tax authorities Mo Malhotra, Ariel Krinshpun and Ockie Olivier evaluate how the OECD guidance on financial transactions will influence an increasingly convoluted transfer pricing environment. By Ariel Krinshpun & Deloitte Transfer Pricing Global & Mo Malhotra & Ockie Olivier September 24 2020
This content is from: Sponsored Surge in data analytics enhance efficiency of transfer pricing audits Eric Lesprit, Mariusz Każuch and Howard Osawa look at three national case studies and consider whether the increased use of international data improves cooperation among tax administrations. By Deloitte Transfer Pricing Global & Eric Lesprit & Howard Osawa & Mariusz Każuch September 24 2020
This content is from: Sponsored Exploring four recent transfer pricing cases Deloitte’s practitioners from across the globe report on four of the most prominent transfer pricing (TP) controversy cases from the recent past: Adecco (Denmark), Glencore (Australia), Cameco (Canada), and Philips (F... By Belinda Kiem & Christopher Thomas & Deloitte Transfer Pricing Global & Kasper Toftemark & Marie-Charlotte Mahieu & Richard Garland September 24 2020
This content is from: Sponsored Testing the meaning of the arm’s-length principle in 2020 and beyond Kerwin Chung and Iva Georgijew assess the impact of the coronavirus pandemic on global transfer pricing and consider how the concept of the arm’s-length principle will subsequently evolve. By Deloitte Transfer Pricing Global & Iva Georgijew & Kerwin Chung September 24 2020
This content is from: Sponsored Transfer pricing controversy: Settling into the new normal Paul Riley, Shaun Austin and John Breen preview ITR’s controversy guide, produced in collaboration with global transfer pricing (TP) experts from Deloitte. By Deloitte Transfer Pricing Global & John Breen & Paul Riley & Shaun Austin September 24 2020
This content is from: Sponsored Getting ahead of the next transfer pricing challenge In collaboration with experts from Deloitte, ITR brings you exclusive insight into how transfer pricing (TP) controversy is evolving as global businesses go through a transformative phase in 2020. By Prin Shasiharan September 24 2020
This content is from: Sponsored Reducing tax uncertainty in Latin America through APAs Ramón López de Haro and Alejandro Paredes evaluate how promoting the negotiation of advance pricing agreements (APAs) may raise the confidence of potential investors in the region. By Alejandro Paredes & Deloitte Transfer Pricing Global & Ramón López de Haro September 24 2020
This content is from: Sponsored The rise and rise of mutual agreement procedures in the EU Eddie Morris, Jennifer Breeze and Janelle Sadri discuss how the growth in the number of mutual agreement procedures, coupled with fine-tuning of the process, has affected its themes of access, resolution and implement... By Deloitte Transfer Pricing Global & Edward Morris & Janelle Sadri & Jennifer Breeze September 24 2020
This content is from: Sponsored The state of transfer pricing controversy in Asia’s leading markets Aaron Wang, Vrajesh Dutia and Chris In explain how adopting global best practices has proved to be beneficial for the development of dispute resolution procedures in China, India and South Korea. By Aaron Wang & Chris In & Deloitte Transfer Pricing Global & Vrajesh Dutia September 24 2020
This content is from: Sponsored How COVID-19 has transformed the hospitality, life sciences and consumer products sectors Deloitte’s Jacqueline Doonan, Aydin Hayri, Oscar Burakoff and Clarke Norton explore the impact that the economic disruption has had on transfer pricing (TP) controversy in the hospitality, life sciences and consumer p... By Aydin Hayri & Clarke Norton & Deloitte Transfer Pricing Global & Jacqueline Doonan & Oscar Burakoff September 24 2020
This content is from: Transfer Pricing Taxpayers turn to business intelligence to improve data quality for TP As more businesses seek to digitalise their tax functions, tax departments are turning towards business intelligence and data analytics to raise data quality and improve transfer pricing and tax efficiency. By Josh White September 23 2020
This content is from: Sponsored US transfer pricing market: Stop thinking about risk and seize the opportunity Oleg Rak of Mason Rak discusses how companies can identify and capitalise on new transfer pricing prospects amid current economic uncertainty. By Mason Rak & Oleg Rak September 23 2020
This content is from: Direct Tax Ending temporary guidance on tax residency adds to PE uncertainty Taxpayers are bracing for profitability and substance challenges because temporary tax guidance on permanent establishment (PE) issues will end and most governments are avoiding discussions on lasting measures that ca... By Danish Mehboob September 21 2020
This content is from: Brazil Tax and TP reform could end Brazil’s adversarial tax culture As Brazil moves towards OECD standards on transfer pricing (TP), there is a broader shift in how the tax authority is dealing with taxpayers to develop a cooperative culture. By Josh White September 17 2020
This content is from: Global Women in Tax Leaders guide 2021 is live: The leading female tax practitioners in the world The sixth edition of the Women in Tax Leaders guide, the leading international publication that lists the world’s top female tax advisors, has released its results for 2021. By Jon Moore September 17 2020
This content is from: Sponsored Women in tax leadership: Staking out a progressive path to partnership Oleg Rak of Mason Rak discusses how global law firms and accountancy firms can use innovative gender equality initiatives to create a more progressive path to partnership for female leaders. By Mason Rak & Oleg Rak September 17 2020
This content is from: Brazil More M&A investments expected in Brazil after tax reform Global tax directors are backing tax reform in Brazil despite short-term uncertainties, including litigation risks, because tax harmonisation with OECD countries will bring in more investment from large businesses. By Danish Mehboob September 14 2020
This content is from: Brazil This week in tax: Taxpayer uncertainty at the Brazil Tax Forum Tax professionals find more uncertainty in international tax this week as the UK steps back on its Brexit promises and experts at ITR’s Brazil Tax Forum think tax reform in Brazil risks more litigation. By Josh White September 11 2020
This content is from: Brazil Why Brazilian tax reform will increase litigation The Brazilian government could cause an increase in litigation in the short-term by its ambitious tax reform. Nevertheless, many businesses see this as a necessary evil to achieve fundamental change. By Josh White September 10 2020
This content is from: Tax Disputes New Zealand Court of Appeal rules against Frucor Soft drinks company Frucor Suntory has lost its court battle with Inland Revenue to defend the tax implications of its past financing arrangements. By Josh White September 10 2020
This content is from: Global This week in tax: Pillar one and pillar two documents are leaked In the week that the OECD’s pillar one and pillar two documents were leaked, the tax world also grappled with more US regulations and a range of tax cuts and expected future rate rises. By Anjana Haines September 04 2020
This content is from: Sponsored Belarus unveils new transfer pricing framework Anastasia Mikhailova and Olga Bahar of KPMG take a closer look at how transfer pricing rules have evolved in Belarus. By Anastasia Mikhailova & KPMG Russia & Olga Bahar September 03 2020
This content is from: Transfer Pricing Countries divided on credit ratings under FTTP guidance The OECD guidance on financial transactions transfer pricing (FTTP) has answered many questions, but it leaves open the potential for serious disagreements about credit ratings in different countries. By Josh White September 03 2020
This content is from: Global Countries clash over scope of Amount B in pillar one tax proposals The OECD faces opposing views about the scope of Amount B in its pillar one proposal, including calls for a broader baseline activity test and demands to keep the focus on marketing and distribution activities. By Anjana Haines September 03 2020
This content is from: OECD Corporate segmentation holds the key to pillar one blueprint Establishing segments and different entity levels within a group of companies may answer some of the questions the OECD is grappling with on the scope of Amount A in the pillar one blueprint. By Anjana Haines September 03 2020
This content is from: Sponsored How to justify your transfer pricing license agreements during COVID-19 Yves Hervé and Philip de Homont of NERA Economic Consulting assess how companies can suitably address concerns surrounding transfer pricing (TP) license agreements. By Nera & Philip de Homont & Yves Hervé September 02 2020
This content is from: Transfer Pricing Companies facing tax scrutiny turn to OTP innovation Businesses operating across the Asia Pacific region are updating their operational transfer pricing (OTP) systems to pre-empt difficult questions from tax authorities. By Josh White September 01 2020
This content is from: OECD OECD says COVID tax guidelines will not modify TP guidance The OECD aims to complete its guidance on dealing with COVID-related transfer pricing (TP) issues by November, but stresses it will not be classed as an amendment to the Transfer Pricing Guidelines (TPG). By Anjana Haines September 01 2020
