A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
A company risks double taxation, penalties and inquiry cost if it submits a form with anomalies under the new system, Asker Ali also tells ITR
Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
Stephanie Pantelidaki’s economic expertise will give Norton Rose Fulbright’s other teams ‘extra firepower,’ she says
Sponsored
Sponsored
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Sponsored by Steadfast Business ConsultingMithilesh Reddy of Steadfast Business Consulting says multinationals must adopt proactive governance and robust compliance practices as the region’s transfer pricing environment develops at pace -
Sponsored by Garrigues SpainRafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied
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Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks
An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations
The case sits within a context of Brazil signalling that it is replacing informal discretion and ambiguity with structures that reward analytical rigour, one expert tells ITR
Significant changes include an update to profit markers and an alteration to how an ‘inbound distributor’ is defined
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR
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
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
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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