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Tax advisors, accountants, banks, lawyers, and other intermediaries who design and promote potentially aggressive cross-border tax planning schemes and, in some cases, the clients that receive such advice, would be required to meet new reporting. . .
India transfer pricing and tax litigator Ajit Jain discusses new transfer pricing rules providing for secondary adjustments . . .
Canadian and US tax officials on June 7 signed a competent authority agreement detailing the planned exchange of annual country-by-country reports on the tax affairs of multinational . . .
Irish chartered accountant JP Canavan discusses Ireland's decisions regarding the BEPS multilateral instrument, including the effect of its selections regarding permanent establishments, dual residents, and tax treaty abuse . . .
Draft OECD transfer pricing guidelines on related party financial transactions, slated for release this summer, will include important guidance for multinationals on intercompany loans, cash pooling, and reinsurance, though reaching consensus among countries on some fundamental issues is . . .
The OECD announced June 9 that Botswana has joined the “Inclusive Framework on BEPS,” becoming the framework's 99th member. The . . .
India transfer pricing specialist Ajit Jain discusses the government's June 7 decision to add a new transfer pricing safe harbor for low-value adding intragroup services and reduce existing safe harbor margins for knowledge process outsourcing services, contract research and development services, and other services.. . . .
BaseFirma, an international transfer pricing advisory firm with a major presence in Latin America, has joined Duff & Phelps' Transfer Pricing Alliance, Duff & Phelps announced . . .
Eight countries are working on a new program to jointly review large multinationals' tax affairs and, if appropriate, provide assurances to the multinational that it will not likely be audited in those jurisdictions with respect to specific tax risks, officials said June 6 in Washington at a conference sponsored by the OECD, USCIB, . . .
India transfer pricing specialist Ajit Jain discusses a tribunal decision that adopts a new way to analyze advertisement, marketing, and promotional expenses for transfer pricing purposes. . .
Zara Ritchie and Natalya Marenina of BDO discuss the implications of May 16 Australian Taxation Office (ATO) guidance setting out the ATO's risk assessment framework for cross-border related party financing . . .
Davide Anghileri of the University of Lausanne discusses an ECOFIN deal, reached May 23, for a directive that will create a new system for resolving double taxation disputes between the EU States; he also provides an update of EU discussions on adopting a common corporate tax base (CCTB) . . .
Mumbai chartered accountant, Ajit Jain, discusses progress and problems with India's advance pricing agreement (APA) program . . .
The OECD today released a discussion draft providing guidance to tax administrations on how to implement transfer pricing guidelines on transfers of hard-to-value intangibles. An approach to hard-to-value . . .
Duff & Phelps, a global valuation and corporate finance advisor firm, announced May 16 that it has acquired Quantera Global Asia Holding, a transfer pricing . . .
The Australian Taxation Office on May 16 issued draft guidelines on cross-border related party financing arrangements. In the . . .