This content is from: Sponsored OECD explores dispute resolution improvements Mark Martin and Thomas Bettge of KPMG in the US describe the OECD’s recent proposals for strengthening the Action 14 minimum standard, and explore how adopting these proposals could improve dispute resolution. By KPMG US & Mark Martin & Thomas Bettge January 28 2021
This content is from: Transfer Pricing The rise of alternative rates to hit TP inter-company loans The London inter-bank offered rate (Libor) is due to disappear at the end of 2021. This might not matter if Libor were not the key reference rate in capital markets. By Josh White January 28 2021
This content is from: Direct Tax Rising Stars Awards Americas 2020 – Winners Announced! All of the winning up and coming stars in their countries and practice areas announced today By James Wilson January 28 2021
This content is from: Transfer Pricing ITR Global Tax 50 2020-21: Stewart Brant The OECD's head of TP Stewart Brant talks to ITR about the team's work on pillar one in 2021 and a new knowledge-sharing initiative. By Josh White January 27 2021
This content is from: Sponsored New IRS policy restricts telescoping for APA and competent authority resolutions Mark Martin and Thomas Bettge of KPMG in the US discuss the recent IRS announcement on telescoping for advance pricing agreement and competent authority cases, and explore what this means for taxpayers. By KPMG US & Mark Martin & Thomas Bettge January 26 2021
This content is from: Sponsored Tax Insights: Deloitte discuss the impact of tax transformation across the Americas ITR Americas Tax Awards winners Chuck Kosal, Emily VanVleet and John Wells discuss how Deloitte is at the forefront of driving tax transformation, in a podcast. By Chuck Kosal & Deloitte Transfer Pricing Global & Emily VanVleet & John Wells & Prin Shasiharan January 26 2021
This content is from: Sponsored The arrival of DAC6 in Cyprus Konstantinos Nanopoulos, Victoria Iliopoulou and Nicholas Demiroglou of TaxExperts Group explore what the introduction of DAC6 means for Cyprus’s transfer pricing world. By Konstantinos Nanopoulos & Nicholas Demiroglou & TaxExperts & Victoria Iliopoulou January 25 2021
This content is from: Tax Disputes ITR Global Tax 50 2020-21: Achim Pross Achim Pross, head of the International Cooperation and Tax Administration Division at the OECD Centre for Tax Policy and Administration, explains how dispute prevention will be improved over the coming year. By Anjana Haines January 21 2021
This content is from: Tax Disputes Transfer pricing cases to watch in 2021 Companies like Apple, Coca-Cola and Facebook are locked in court battles over their transfer pricing (TP) arrangements. ITR reviews a few of the biggest TP cases for tax professionals to keep an eye on in 2021. By Josh White January 21 2021
This content is from: Sponsored Thailand’s new TP law: Assessing the risks for taxpayers Paul Ashburn and Rohit Sharma of HLB Thailand explore how Thai transfer pricing legislation has evolved to entail greater disclosure requirements and discusses the associated risks for taxpayers. By HLB Thailand & Paul Ashburn & Rohit Sharma January 19 2021
This content is from: Global This week in tax: Heated debate at OECD’s digital tax consultation Six months to agree on the pillar one and pillar two blueprints on how to tax the digitalisation of the economy still seems too ambitious based on the comments made during this week’s OECD public consultation. By Anjana Haines January 15 2021
This content is from: France ITR live: OECD consultation on pillar two The OECD holds its public consultation on its pillar two blueprint to establish a global minimum tax rate, ITR reports live. By Josh White January 15 2021
This content is from: Global ITR Awards 2021 and World Tax/World TP rankings research now open for submissions Companies, firms and individuals can now enter for the 2021 ITR Americas Tax Awards, ITR Asia-Pacific Tax Awards and ITR Europe, Middle East and Africa Awards. By James Wilson & Jon Moore January 14 2021
This content is from: Transfer Pricing Unilever: How the OECD could simplify pillar two Unilever has laid out ways the OECD could reduce the level of complexity in its pillar two proposal for a global minimum tax rate, including measures to safeguard businesses from double taxation. By Josh White January 14 2021
This content is from: France ITR live: OECD consultation on pillar one The OECD holds its public consultation on its pillar one blueprint to reform international tax, ITR reports live. By Josh White January 14 2021
This content is from: United Kingdom HMRC ramps up transfer pricing investigations The UK revenue authority has stepped up its investigations into ‘irregular’ transfer pricing (TP) practices as part of renewed efforts to raise tax compliance. This may lead to yet more penalties and controversy for t... By Josh White January 12 2021
This content is from: Sponsored Italy: The case law on non-interest bearing loans and the arm’s-length principle Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners analyse a recent judicial decision which looks at the tax implications of inter-company transactions in Italy. By Barbara Scampuddu & Gian Luca Nieddu & Hager & Partners January 12 2021
This content is from: Transfer Pricing OECD must clarify coexistence of GloBE and GILTI rules, say MNEs Procter & Gamble, GlaxoSmithKline, Unilever and 46 other companies want the OECD to clarify how the global anti-base erosion (GloBE) proposal under pillar two will interact with US global intangible low-taxed income (... By Josh White January 07 2021
This content is from: India Indian court confirms Redington’s use of foreign subsidiaries avoided tax Sanjeev Sharma, principal director of income tax at the India Income Tax Department, explains why the Madras High Court decided Redington India’s use of foreign subsidiaries to transfer shares offshore was an attempt ... By Sanjeev Sharma January 07 2021
This content is from: Ireland Facebook’s decision to shift IP to US reflects industry tax concerns Facebook’s decision to dismantle three of its Irish holding companies and repatriate its intellectual property (IP) licences back to the US may be a sign of growing of unease in the technology industry. By Josh White January 06 2021
This content is from: Sponsored Germany: Taxation of the digital economy - Analysing user base value Yves Hervé and Philip de Homont of NERA Economic Consulting present a case study on considering the data-based economic valuation of user contributions. By Nera & Philip de Homont & Yves Hervé January 06 2021
This content is from: OECD ITR Global Tax 50 2020-21: Pascal Saint-Amans The director of the OECD Centre for Tax Policy and Administration talks to ITR about pillar one and pillar two, inclusivity in tax, and the power of the coffee break. By Alice Jones January 04 2021
