ITR Awards | International Tax Review
Jul 25, 2024 · Deloitte leaves ITR’s 2024 Awards as biggest winner. The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours. Sam Sholli, September 19, 2024. Awards.
Trump wins: Republicans to preserve expiring tax cuts, experts …
6 days ago · Preparing for Germany’s new and stricter TP documentation rules. Sweeping changes are headed for Germany’s TP system in the New Year. Tax teams will need to be well-prepared, say Andreas Katz and Anna Kupprion of Kreston Bansbach. Andreas Katz, November 07, 2024. This month in indirect tax: EU finalises ViDA proposal.
Understanding the beneficial ownership v. beneficial holding …
Sep 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 ...
This week in tax: Amazon UK ‘pays corp tax for first time since 2020’
Sep 27, 2024 · Amazon’s main UK division has paid corporation tax for the first time since 2020, it was reported yesterday, September 26. Amazon UK Services reportedly paid £18.7 million ($25 million) in “current tax” on sales of £27 billion last year, the majority of which was corporation tax. It has been linked to the end of a ‘super-deduction ...
Deloitte TP Controversy Guide | International Tax Review
Sep 25, 2024 · The shifting tides of TP: a closer look at tax controversy driving legislative changes. Christine Ramsay and Samer Wani of Deloitte Canada and Subhabrata Dasgupta of Deloitte Malaysia highlight significant legislative developments in several jurisdictions as the world strives to keep pace with the OECD's Transfer Pricing Guidelines.
MLI: Testing the ‘principal purpose’ | International Tax Review
Dec 12, 2018 · The MLI essentially allows the tax treaty-related measures of the OECD/G20 BEPS project to be introduced into the existing tax treaties of the signatories to the convention in a consistent and efficient manner, eliminating the need to renegotiate every bilateral tax agreement separately. The MLI positions adopted by each participating ...
IP transfers: Tax and accounting considerations
Dec 17, 2012 · Royalties paid in exchange for the right to use or exploit IP outside of the US are typically foreign-source income – IRC §862(a)(4). In contrast, the gain from the sale of IP – patents, copyrights, secret processes or formulas, goodwill, trademark, trade brand, franchise, or other like property – is generally sourced under IRC §865 according to the residence of the seller.
Transfer Pricing - International Tax Review
Oct 24, 2024 · Dinko Dinev and Adam Wojewoda of Deloitte Luxembourg explore AI’s potential to enhance efficiency in transfer pricing but emphasise the irreplaceable value of human expertise in navigating complex regulatory landscapes. Dinko Dinev, October 25, 2024. Sponsored by EY Romania. Romanian tax authorities ramp up their analysis of intercompany ...
Plastic taxes: a guide to new legislation in Europe
Feb 15, 2023 · The tax rates are €450 (~$465) per ton of taxable plastic in Spain and Italy, and £200 (~$250) per ton in the UK. The expected (net) government revenue from the Italian plastic tax was estimated to be almost €470 million (~$484 million) for the first year, and from the Spanish plastic tax, €724 million ($745) million.
A brave new world in tax transparency: CRS in China, Hong Kong …
November 28, 2017. Increasing cross-border business and investment has made the holding of assets overseas through offshore accounts increasingly common. This has become a new tax battleground for businesses and governments. Charles Kinsley, Henry Wong, and Eva Chow look at the latest developments regarding these efforts in China, Hong Kong and ...