Denmark v EET Group case sets important precedent, say experts
The judgment, which saw Denmark's Supreme Court rely on OECD TP guidance, sets aside more than 15 years of consistent administrative practice, experts have told ITR
Who gets taxed when no one’s there? AI, presence, and profit allocation
In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present
French TP case highlights transaction scrutiny trend: experts
France v Axa provides a practical illustration of how the burden of proof is applied in TP matters under French law, ITR also heard
Navigating hidden contributions and profit distributions in intragroup financing
Edouard Authamayou of Deloitte Luxembourg examines a tribunal ruling on hidden contributions and profit distributions that highlights the importance of robust evidence supporting the arm’s-length principle in intragroup financing arrangements and interest rate waivers
UK TP proposals could ‘double compliance costs’, tax firm warns
Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP
Italian Supreme Court clarifies definition of associated enterprises for transfer pricing purposes
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente examine a recent ruling revisiting how control is defined in the context of transfer pricing regulations
When algorithms decide tax outcomes: embedding ethics in TP systems
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
Experts question whether UK TP proposal is ‘absolutely necessary’
The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
‘Coffee is the only constant’: Raphael Holzinger on the pressures of his practice
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
ITR EMEA Tax Awards 2025: shortlist announced
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards