The firm has appointed Deloitte’s former tax leader for Thailand to lead the new operation, which builds on considerable Asian investment in recent months
The firm is hunting for a senior TP manager in its quest to build a full-service practice in Indonesia, A&M Tax’s Jakarta head Jaap Zwaan tells ITR
The tax technology company will be providing a free demonstration of its OTP software and offering best practice advice on whether to ‘buy or build’ on September 8
The global tax and accounting firm has appointed two experienced TP advisers from a New Jersey-based boutique
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Sponsored by Deloitte LuxembourgEdouard Authamayou of Deloitte Luxembourg examines a tribunal ruling on hidden contributions and profit distributions that highlights the importance of robust evidence supporting the arm’s-length principle in intragroup financing arrangements and interest rate waivers -
Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine a recent ruling revisiting how control is defined in the context of transfer pricing regulations
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Sponsored by DeloitteVanesa Lanciotti of Deloitte Chile explores how recent reforms – including new advance pricing agreement rules, enhanced audit priorities, and disclosure requirements – are reshaping transfer pricing practice and compliance for multinationals operating in Chile
PepsiCo was represented by PwC, while the ATO was advised by MinterEllison, an Australian-headquartered law firm
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
France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard
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
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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 Americas Tax Awards
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