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WEB3 days ago · ITR World Tax rankings released: big EMEA performance for ‘big four’. Tom Baker, September 10, 2024. This week in tax: Ireland progresses with new participation exemption. Ralph Cunningham, August 30, 2024. This month in indirect tax: UK parties say no to higher VAT. Ralph Cunningham, June 05, 2024.
Understanding the beneficial ownership v. beneficial holding …
WEBSep 14, 2021 · The concept of ‘beneficial ownership’ is found under the international tax treaties. The tax treaties are negotiated based on the model tax conventions and these conventions inter alia provide explanations as to the intent and purpose behind terms appearing therein. The phrase ‘beneficial owner’ appears in both the OECD Model Tax Convention and the UN Model Tax Convention in the ...
Transfer Pricing | International Tax Review
WEB6 days ago · ITR is delighted to reveal all the shortlisted nominees for the 2024 Asia-Pacific Tax Awards. John Harrison, July 25, 2024. Transfer Pricing. Luxembourg Transfer Pricing Association launched. There is a 'critical need' for a unified platform to address challenges in TP, the organisation’s president told ITR. Sam Sholli, July 24, 2024.
Intangibles and DEMPE analysis: on tax authorities’ radars worldwide
WEBFeb 21, 2023 · In the above cases, as stated in Chapter 6 of the OECD Transfer Pricing Guidelines, 2022, it is necessary to analyse the so-called development, enhancement, maintenance, protection and exploitation (DEMPE) functions (and associated risks), with the aim of identifying which entity involved in the transaction performs these functions.
Argentina - International Tax Review
WEBExclusive: Brazil’s draft reform offers tax planning disclosure rule, say sources. Tax professionals are divided about the impact of the draft transfer pricing legislation in Brazil, while everyone waits for the incoming government to make the final decisions. Siqalane Taho, December 15, 2022.
The long expected Brazilian tax reform – objectives, challenges and ...
WEBMar 30, 2020 · The Brazilian government and the Congress began 2020 by reiterating that reforming the tax system is one of the main priorities and that the initial objective is to consolidate the different propositions into a single project, which would follow the legislative process within the House of Representatives and the Senate.
Conferences | International Tax Review - ITR
WEBApr 25, 2024 · ITR produces 8 high-level conferences and summits a year which attract over 1,000 attendees. For more information, contact: Jamil Ahad, Commercial Director. [email protected]. +44 (0) 207 779 8767. Jamil heads up …
Why the US-Luxembourg treaty brings long-awaited benefits
WEBSep 30, 2001 · The changes in withholding tax for a US corporate investor are summarized in Table 1 above. Luxembourg investment into the US. For Luxembourg resident companies, the main difference between the old treaty with the US and all other Luxembourg treaties was that the method for avoiding double taxation used a credit rather than an exemption approach.
The IRS takes Facebook to court over its Irish tax structure
WEBFebruary 19, 2020. The US Tax Court will decide whether Facebook owes more than $9 billion to the Internal Revenue Service (IRS) in a landmark case. This would hit the company’s cash reserves hard. The IRS is challenging Facebook on its transfer pricing arrangements in Ireland to as far back as 2010. The revenue service have accused the ...
Top 10 transfer pricing cases from 2022 | International Tax Review
WEBDecember 12, 2022. ITR picks 10 cases that made the headlines, with McDonald’s France, BlackRock, and Maersk Oil and Gas all making the list. It’s time for ITR’ s annual review of the biggest transfer pricing disputes of the year. Once again, multinationals found themselves up against determined tax authorities in high-stakes cases across ...