New reforms represent the most seismic shift in Canadian TP legislation since its enactment and a clear inflection point for MNEs, ITR has heard
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
As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management
Sponsored
Sponsored
-
Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Crowe Valente/Valente Associati GEB Partners consider the ramifications of a ruling concerning the inclusion of loss-making companies in a transfer pricing benchmarking analysis as comparable entities -
Sponsored by Spanish VAT ServicesFernando Matesanz of Spanish VAT Services reports on a pronouncement by an EU member state on the impact that transfer pricing adjustments have on the VAT applied to transactions
-
Sponsored by Lakshmikumaran & SridharanKaranjot Singh Khurana of Lakshmikumaran & Sridharan presents an Indian perspective on the transfer pricing implications of multinational corporations entering into global contracts that could affect group entities
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
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights 'significant concerns'
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
-
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