Bilateral APAs have their moment
For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality
India’s record APAs a win for government efficiency: experts
The promise of nine years’ tax certainty and a ‘rational and pragmatic’ government process makes APAs a no-brainer, Indian tax advisers tell ITR
Fixing Italy’s approach to taxing digital business
Despite garnering significant revenues from multinationals, Italy’s digital services tax presents pressing double taxation issues, say Stefano Simontacchi and Francesco Saverio Scandone of BonelliErede
‘General pause’ on pillar one in many countries: BDO tax leader
The US needs to be involved in pillar one for there to be more international acceptance of the project, Michael Masciangelo says
Decoding intellectual property ownership: insights from Swedish transfer pricing case law
Mikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters
Recent Korean TP precedents: practical implications for policy and compliance
With South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy
The periodicity principle v OECD guidance: Swiss court rejects multi-year margin averaging
Monika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance
Italy: Renewed focus on tariffs and transfer pricing interplay after Trump measures
Multinational groups may need to reassess their strategies in the wake of the US president’s sweeping tariff changes. Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente outline ways to mitigate the impact
US foreign tax credit rules: impact on Brazilian withholding taxes
Taxpayers with Brazilian operations should revisit their withholding positions in light of updated US guidance, writes Rafael Benevides, senior tax counsel at Meta
‘No avenue for effective judicial oversight’: Experts on Canada TP case
The MEGlobal Canada decision highlights taxpayers’ frustrations over split jurisdiction for TP assessments as well as a need for legislative reform, one expert tells ITR