The country has overseen better audit procedures and demonstrated commitment to acting as a 'regional leader' on international tax matters, the OECD said
Darren Graves will succeed Richard Houston, who is set to lead Deloitte EMEA; in other news, Morgan Lewis hired a three-partner tax team in New York
India also signed its first-ever bilateral APAs with France, Ireland, Indonesia and Sweden last year, the CBDT revealed
New reforms represent the most seismic shift in Canadian TP legislation since its enactment and a clear inflection point for MNEs, ITR has heard
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Sponsored by MathesonOn October 9 2018, Ireland's Minister for Finance, Public Expenditure and Reform Paschal Donohoe announced budget 2019. On October 18 2018, the draft legislation to implement the budget was published. In furtherance of Ireland's obligations under the EU Anti-Tax Avoidance Directive (ATAD), Donohoe announced the introduction of a new controlled foreign companies (CFC) regime and an ATAD-compliant exit charge. The exit charge took effect from October 10 2018 and the CFC rules will apply to accounting periods beginning on or after January 1 2019.
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Sponsored by Deloitte MexicoMexico's First Circuit Court has recently ruled against a taxpayer in a case involving two transfer pricing adjustments that will make it tougher for companies to comply with their domestic tax obligations on time. -
Sponsored by NeraThe combined effect of the globalisation of entrepreneurial responsibilities within multinationals and the OECD's BEPS initiative puts traditional one-sided transfer pricing (TP) methods under increased pressure. NERA Managing Director Dr Yves Hervé and Associate Director Philip de Homont show how transactional net margin method (TNMM)-type TP solutions can be made sustainable for the future.
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution
Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said
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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 submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
The boutique Australian firm’s TP award recognition proves that world-class advisory services aren’t limited to the ‘big four’, the firm’s founder tells ITR
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
Awards
The ‘big four’ firm scooped over 60 honours at a lively ceremony held at The Londoner hotel, including both EMEA and APAC Tax Advisory Firm of the Year