Home | International Tax Review
Oct 14, 2011 · Tom Ravlic, October 18, 2024. This week in tax: Ex-lawyer faces prison over $2.5m tax avoidance. The former Husch Blackwell attorney failed to pay income tax despite living lavishly; in other news, Italy vows to strengthen digital services tax. Sam Sholli, October 18, 2024. ‘An uncertain environment’: US experts criticise IRS TP memorandum.
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 …
ITR Awards | International Tax Review
Sep 27, 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.
Conferences | International Tax Review - ITR
Sep 26, 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 business development for ITR events. He helps firms network, engage and do business with tax and TP …
Transfer Pricing - International Tax Review
Oct 10, 2024 · Transfer Pricing. CMS highlights from ITR’s Transfer Pricing Forum: The Italian perspective. Vittoria Segre, partner at CMS Italy, reviews a range of TP topics discussed at the event, including financial transaction audits and permanent establishment issues. Vittoria Segre, September 26, 2024. Transfer Pricing.
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.
The long expected Brazilian tax reform – objectives, challenges and ...
Mar 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.
Tax technology: a powerful ally in the race against regulation
Jan 2, 2024 · The future of tax technology. The future of tax technology is promising. Advancements in AI, machine learning, and robotic process automation (RPA) are revolutionising tax compliance. AI-powered tax software can automatically categorise and analyse transactions, identify tax-related issues, and even predict regulatory changes.
Transfer pricing in Indonesia: an overdue revamp
Feb 29, 2024 · The past decade has seen Indonesia issuing transfer pricing regulations on an annual basis, making it one of the most advanced transfer pricing regimes and highly dynamic transfer pricing audit environments in the region. However, the recently issued Minister of Finance Regulation No. 172/2023 on the Implementation of the Arm’s Length ...
ITR World Tax rankings released: global firms dominate
August 21, 2024. As ITR’s accreditation title releases its global rankings, we focus on the top performers that excelled in multiple tax disciplines across various jurisdictions. To mark the much-anticipated release of the World Tax rankings today, August 21, ITR has taken a top-down view of the best performers on an international scale.