The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says
Taxpayers with Brazilian operations should revisit their withholding positions in light of updated US guidance, writes Rafael Benevides, senior tax counsel at Meta
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
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Sponsored by DeloitteWith ever-increasing challenges in the wholesale and retail industry, senior tax practitioners at Deloitte Germany consider the impact of amount B on the profit allocation of multinationals operating in the sector -
Sponsored by DeloitteIshan Maini of Deloitte UK and Jay Das of Deloitte US say the need for technology, media, and telecommunications companies to analyse the risks associated with intercompany transactions has never been greater
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Sponsored by DeloitteClaudia Lauten, Janis Sussick, and Karen Smolka of Deloitte discuss how amount B could impact the tax and transfer pricing approaches of global multinational enterprises in the industrial products and construction sector
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
Other reasons included the complexity of reporting, resource constraints and interactions with tax administrations
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR
The court emphasised that TP analysis must adhere to the arm's-length principle, be based on the specific facts of each transaction and comply with domestic regulations, one expert says
The ruling in January was the first time the court had unanimously upheld a taxpayer's position in a case concerning TP, according to a lawyer who worked on the case
The change is understood to include enhancing information comparison
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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