ATO attempts to clarify stance on inbound cross-border related party debt and risk factors
Sarah Gard of DLA Piper Australia summarises the Australian Taxation Office’s draft guidance on determining whether the amount of inbound, cross-border related party debt is consistent with the arm’s-length conditions for transfer pricing purposes
Scanning intragroup royalty payments through the lens of the OECD’s BEPS projects
Andrew Jackomos and Amit Bhalla of HLB Thailand examine how evolving global tax standards are reshaping the treatment of intragroup royalty payments and driving stricter compliance and documentation requirements
EY expert highlights ‘additional practical complexities’ around pillar two implementation
While pillar one is still alive, it will apply to a smaller group of companies, Brian Foley also told ITR
India: Key transfer pricing issues with global capability centres
While GCCs drive efficiency for multinationals, they also present a host of TP risks that should be considered carefully
Italy: Transfer pricing of financial transactions – proper classification and recharacterisation risk
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine how the Italian tax authorities scrutinise financial transactions and cash pooling arrangements, with potential recharacterisation risks under transfer pricing rules
‘Amazing timing’: Aibidia on expanding AI TP solutions in US
Following a $28 million funding round, Aibidia wants to ‘double down’ on the US market via partnerships with the ‘big four’, the Finnish TP tech provider’s CEO tells ITR
Five minutes with…Antonio Weffer, Baker McKenzie
The Luxembourg-based TP leader tells ITR about relishing the intellectual challenge of his practice, his admiration for Stephen Hawking, and what makes tax cool
Five minutes with…Lennart van den Kommer, Reptune
The Dutch TP software company’s co-founder tells ITR about speeding up documentation processes, following in Steve Jobs’s footsteps, and what makes tax cool
‘Significant implications’: Experts analyse US v Facebook TP ruling
The ruling underscores the need for companies to provide robust and defensible valuations of intangible assets, one partner tells ITR
WTS Germany acquires Baker McKenzie tax team in post-investment play
The arrival of a seven-strong team from Baker McKenzie will boost WTS Germany’s transfer pricing capabilities and help it become ‘a European champion’, the firm’s CEO said