ATO releases updated APA instructions, warns of 'collateral issues'
APAs should provide a pragmatic means to agree to an arm's-length outcome for an Australian entity and for the ATO, the tax authority said
Debt pricing studies and automation: benefits and risks
Dinko Dinev of Deloitte Luxembourg explores how automation is transforming debt pricing studies in transfer pricing, highlighting efficiency gains but also analytical risks that can arise if technology is misapplied
This week in tax: Netflix shares fall after $619m tax dispute with Brazil
The streaming company’s operating income was $400m below expectations following the dispute; in other news, the OECD has released updates for 25 TP country profiles
HSF Kramer client Oracle scores Australia MAP court win
Software company Oracle has won the right to have its A$250m dispute with the ATO stayed, paving the way for a mutual agreement procedure
TP challenges in West and Central Africa
TP is a growing priority for West and Central African tax authorities, writes Winnie Maliko, but enforcement remains inconsistent, and data limitations persist
Becoming 'the firm of choice': Ryan president on Dhruva investment
Increasingly, clients are looking for different advisers to the established players, Ryan’s president for European and Asia Pacific operations tells ITR
Italy: Preventing and resolving double taxation in transfer pricing
The Italian framework for tax certainty has been reinforced through advance pricing agreements, mutual agreement procedures, and other dispute resolution tools, explain Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente
‘No way around it’: TP expert slams Trump’s ‘Liberation Day’ tariffs
The tariffs are disrupting global supply chains and creating a lot of uncertainty, tax expert Miguel Medeiros told ITR’s European Transfer Pricing Forum
OECD victim of own success with MAPs: tax certainty co-head
MAP cases keep increasing, and cases closed aren’t keeping pace with the number started, the OECD’s Sriram Govind also told an ITR summit