This content is from: Tax Disputes OECD's Achim Pross to focus on disputes, MAPs and APAs in 2021 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
