Tax auditors themselves had not been aware of the new TP ‘transaction matrix’ requirements, ITR hears as five German partners share their client experiences
The judgment, which saw Denmark's Supreme Court rely on OECD TP guidance, sets aside more than 15 years of consistent administrative practice, experts have told ITR
In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present
France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard
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Sponsored by DeloitteMario Coyoy of Deloitte S-LATAM and Michelle Martinelli of Deloitte Panama note increasing transfer pricing scrutiny in several Central American jurisdictions as they step up their attempts to enhance transparency and ensure compliance -
Sponsored by DeloitteVanesa Lanciotti of Deloitte Chile explains the country’s key transfer pricing-related measures as it seeks to increase its tax collection by 1.5% of GDP, with a new focus on tax compliance and financial governance
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Sponsored by DeloitteCarlos Ayub of Deloitte Brazil focuses on the challenges for organisations that trade commodities under the country’s new transfer pricing legislation and explains what methods and courses of action are available to in-scope taxpayers
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Representatives from the two countries focused on TP as they met this week to evaluate progress under a previously signed agreement – it is understood
While pillar one is still alive, it will apply to a smaller group of companies, Brian Foley also told ITR
An Administrative Review Tribunal ruling last month in Australia v Alcoa represents a 'concerning trend' for the tax authority, one expert tells ITR
The plan aims to improve the efficiency, transparency, and effectiveness of direct tax administration in India
The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says
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
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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 is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
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