http://www.internationaltaxreview.comhttp://feeds.feedburner.com/internationaltaxreview/pbVq©2019 International Tax Review60Transfer PricingItaly has recently implemented a new procedure to mitigate double taxation arising from foreign transfer pricing adjustments. Chiomenti’s Raul-Angelo Papotti, Paolo Giacometti and Andrea Alcara discuss the procedure, conditions and mandatory elements that must be addressed in order for an enterprise to seek an adjustment.http://www.internationaltaxreview.com/Article/3883378/Italy-addresses-double-taxation-arising-from-foreign-TP-adjustments.htmlThu, 11 Jul 2019 13:00:00 GMTLuxembourg’s stability and innovative culture has made it a global leader in the financial services sector. However, the greater interaction between the tax and regulatory dimension is creating complex tax governance and controversy challenges. Deloitte Luxembourg’s Ralf Heussner and Enrique Marchesi-Herce explore the impact BEPS changes will have on Luxembourg and its financial services sectorhttp://www.internationaltaxreview.com/Article/3883380/Transfer-pricing-controversy-and-governance-challenges-in-Luxembourg.htmlThu, 11 Jul 2019 13:00:00 GMTIn twenty short years, Russia has undergone a rapid transformation in transfer pricing (TP) adoption and harmonisation with the OECD’s norms. EY CIS’s Evgenia Veter traces the nation’s adoption, evolution and future development of TP policy, while exploring the key areas Russian tax authorities have currently highlighted as their focushttp://www.internationaltaxreview.com/Article/3883381/Russias-20-year-evolution-of-transfer-pricing-practices.htmlThu, 11 Jul 2019 13:00:00 GMTTax leaders from Barilla, Repsol and Shell have encouraged their contemporaries to sign up for the International Compliance Assurance Programme (ICAP), before the window to get involved closes later this month.http://www.internationaltaxreview.com/Article/3879943/Tax-heads-encourage-more-companies-to-use-ICAP.htmlWed, 10 Jul 2019 09:30:00 GMTRocío Bermúdez, tax global practices & transfer pricing senior manager at Repsol, spoke to ITR about her company’s participation in the first pilot of the International Compliance Assurance Programme.http://www.internationaltaxreview.com/Article/3879433/Case-study-Repsols-participation-in-ICAP.htmlWed, 10 Jul 2019 09:30:00 GMTWhile feedback on the International Compliance Assurance Programme (ICAP) has been overwhelmingly positive, unsurprisingly, the first pilot did encounter some teething problems.http://www.internationaltaxreview.com/Article/3880053/The-negative-aspects-of-ICAP.htmlWed, 10 Jul 2019 09:30:00 GMTThe OECD’s Achim Pross says his ultimate aim is to expand the International Compliance Assurance Programme (ICAP), but companies may be disappointed to learn that it could be a relatively slow process.http://www.internationaltaxreview.com/Article/3880116/OECD-wont-rush-ICAP-expansion-despite-schemes-popularity.htmlWed, 10 Jul 2019 09:30:00 GMTMultinationals in Argentina may want to rethink the way they operate in the country to take advantage of tax benefits available from 2020 under the new tax promotional regime for the so-called knowledge-based economy.http://www.internationaltaxreview.com/Article/3883334/Argentina-New-tax-promotional-regime-for-knowledge-based-activities.htmlWed, 10 Jul 2019 09:30:00 GMTThe OECD’s Inclusive Framework countries have agreed to a 40-page report that outlines potential ways to tax the digital economy. The document suggests, among other measures, introducing worldwide fractional apportionment for corporate profits.http://www.internationaltaxreview.com/Article/3876448/OECD-to-consider-worldwide-fractional-apportionment.htmlFri, 31 May 2019 11:00:00 GMTWithholding taxes represent legal obligations of monies payable to a taxing authority by a payor in Country A to a payee recipient in Country B.http://www.internationaltaxreview.com/Article/3875751/Withholding-tax-Complexity-and-inequality.htmlTue, 28 May 2019 13:00:00 GMTThe BEPS project has had a fundamental impact on how multinational companies are structuring their intangible assets. Josh White investigates how businesses are reorganising their tax arrangements to meet their commercial needshttp://www.internationaltaxreview.com/Article/3875757/Intangibles-Re-engineering-substance.htmlTue, 28 May 2019 13:00:00 GMTThe consultation period for feedback on India’s proposed changes to its profit-attribution rules has not yet ended, but the debate around the potential costs and benefits of any change is already hotting up.http://www.internationaltaxreview.com/Article/3874028/Taxpayers-say-Indias-proposed-move-to-fractional-apportionment-would-intensify-disputes.htmlWed, 15 May 2019 15:30:00 GMTThe nominations for the 15th annual ITR European Tax Awards have been announced.http://www.internationaltaxreview.com/Article/3866261/ITR-European-Tax-Awards-2019-shortlist-announced.htmlWed, 27 Mar 2019 17:00:00 GMThttp://www.internationaltaxreview.com/Article/3860783/What-you-need-to-know-before-taking-out-tax-insurance.htmlThu, 21 Mar 2019 11:30:00 GMTTax insurance, which helps companies to push through deals with identified tax risks, is being used needlessly on tax issues which present barely any risk at all, according to one tax director, but others disagree.http://www.internationaltaxreview.com/Article/3862879/The-negative-aspects-of-tax-insurance.htmlWed, 06 Mar 2019 14:15:00 GMTThe Canadian firm Bennett Jones has appointed Ed Kroft, Jehad Haymour, and Deborah Toaze as partners and Sophie Virji and Eric Brown as associates to the Vancouver, Calgary and Toronto offices.http://www.internationaltaxreview.com/Article/3846389/Bennett-Jones-adds-five-to-its-tax-team.htmlWed, 28 Nov 2018 14:15:00 GMTGlenn Price, head of international tax at Vodafone, talks to Josh White about the risks taxpayers face in an increasingly uncertain world.http://www.internationaltaxreview.com/Article/3838319/Vodafones-Glenn-Price-talks-tax-and-risk.htmlMon, 15 Oct 2018 13:00:00 GMTA suite of mutually reinforcing measures with an overall focus on resolution at the earliest point in time is the ultimate goal for taxpayers and tax authorities. Achim Pross, Sandra Knaepen and Mark Johnson of the OECD describe the organisation’s comprehensive dispute resolution agenda, both within and beyond the BEPS project.http://www.internationaltaxreview.com/Article/3775502/Embracing-tax-certainty-through-improved-dispute-resolution.htmlThu, 14 Dec 2017 11:30:00 GMTThe tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.http://www.internationaltaxreview.com/Article/3744473/EU-holding-company-structure-in-treaty-shopping-cases.htmlWed, 23 Aug 2017 13:30:00 GMTThe nominees for the 12th annual Americas Tax Awards have been announced.http://www.internationaltaxreview.com/Article/3734700/Americas-Tax-Awards-2017-Shortlists-announced.htmlWed, 19 Jul 2017 17:30:00 GMTTwenty eight different firms, individuals and companies shared the prizes at the Asia Tax Awards in Singapore.http://www.internationaltaxreview.com/Article/3714970/Asia-Tax-Awards-2017-winners-announced.htmlThu, 04 May 2017 15:30:00 GMTTirthesh Bagadiya of Bagadiya & Jain looks at what he sees as the beginning of a new era in Indian transfer pricing regulationshttp://www.internationaltaxreview.com/Article/3665405/Welcome-to-the-world-of-secondary-adjustments.htmlTue, 28 Feb 2017 11:00:00 GMTThe EU Economic and Financial Affairs Council (Ecofin) has agreed on measures to help establish a tax blacklist of uncooperative jurisdictions.http://www.internationaltaxreview.com/Article/3600179/EU-Council-agrees-on-criteria-to-establish-tax-blacklist.htmlTue, 08 Nov 2016 17:00:00 GMTIKEA has lost an important tax battle that could have implications for other multinationals deducting interest on inter-company debt.http://www.internationaltaxreview.com/Article/3596518/IKEA-Handel-og-Eiendom-loses-Supreme-Court-of-Norway-tax-case.htmlWed, 26 Oct 2016 16:30:00 GMTThere have been a number of significant developments in the area of US tax controversies during 2016. Fenwick & West highlight some of the top US tax cases from this year, including several large § 482 transfer pricing cases that could provide helpful insight for taxpayers who may be facing similar significant transfer pricing adjustments.http://www.internationaltaxreview.com/Article/3590815/The-top-US-tax-controversies-in-2016.htmlFri, 07 Oct 2016 17:00:00 GMTMcDermott Will & Emery, the winner of the Americas Tax Firm of the Year, has shown the greatest strength in depth on both continents. The firm was honoured at the Americas Tax Awards in New York on September 15 2016. Deloitte were honoured as Transfer Pricing Firm of the Year.http://www.internationaltaxreview.com/Article/3590380/Americas-Tax-and-Transfer-Pricing-Awards-2016.htmlMon, 03 Oct 2016 12:00:00 GMTWeeks before the US election, the Global Transfer Pricing Forum in New York will hear from economic advisers to the Republican and Democratic candidates on September 22 & 23.http://www.internationaltaxreview.com/Article/3584947/US-presidential-advisers-to-address-Global-Transfer-Pricing-Forum.htmlMon, 12 Sep 2016 14:00:00 GMTWhile Apple was unveiling the iPhone 7 in California, thousands of miles away Ireland’s parliament was locked in a bitter debate over a European Commission order to collect $14.5 billion in back taxes from the tech giant. The debate was fiery but the vote results were decisive.http://www.internationaltaxreview.com/Article/3583699/VIDEO-Ireland-votes-on-Apple-tax-appeal.htmlWed, 07 Sep 2016 14:15:00 GMTThe UK is debating whether Britain should become one of the first countries in the world to introduce public country-by-country reporting (CbCR). The measure is one of many tax proposals on the parliamentary agenda, including lowering the corporate tax rate.http://www.internationaltaxreview.com/Article/3583246/UK-parliament-debates-public-country-by-country-reporting.htmlMon, 05 Sep 2016 13:15:00 GMTIrish politicians have a €13 billion ($14.5 billion) decision to make on Wednesday. Should they appeal the EC's order to collect Apple’s back taxes or take the money and run? The windfall is enough to cover Ireland’s entire health care budget, or pay for more than 30,000 new homes, or buy 2.6 billion pints of Guinness.http://www.internationaltaxreview.com/Article/3583098/Ireland-has-a-13-billion-headache-plus-interest.htmlMon, 05 Sep 2016 00:15:00 GMT