Home | International Tax Review
4 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, …
EY Asia-Pacific Guide | International Tax Review - ITR
Dec 14, 2023 · EY’s Asia-Pacific Guide 2023: Transformational tax trends. ITR has collaborated with EY to provide insights into the most pressing tax issues in the Asia-Pacific region as the pace of change shows no sign of abating. Sponsored by EY Asia-Pacific. BEPS 2.0: the implementation of pillar two in Asia-Pacific. Senior EY tax practitioners provide ...
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.
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 ...
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.
News - International Tax Review
4 days ago · Trump wins: Republicans to preserve expiring tax cuts, experts predict. Local experts say the Tax Cuts and Jobs Act is due a revival after Donald Trump won the US presidential election. Sam Sholli, November 06, 2024. Transfer Pricing.
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 ...
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 ...
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.
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.