by usoftax_admin | Sep 25, 2024 | Tax News
Nicola Lostumbo and Jie Pan of Deloitte provide insights into high-value intercompany service charges, their role in creating value, and the most common tax authority challenges, before concluding with some considerations in mitigating risks by usoftax_admin | Sep 25, 2024 | Tax News
With the pricing of intangibles laced with difficulty, Ishan Maini, Eric Linge, and Richard Schmidtke of Deloitte draw on two cases in Germany and Israel revolving around differing interpretations concerning the delineation of transactions by usoftax_admin | Sep 25, 2024 | Tax News
The complex distinction between legal ownership and economic ownership of intangible assets means multinationals must take proactive measures to avoid transfer pricing controversy, say Christine Ramsay, Jordi Morera, and Marguerite Mei of Deloitte by usoftax_admin | Sep 25, 2024 | Tax News
Vrajesh Dutia and Michael Nixon of Deloitte explain the nuances of amount B as jurisdictions consider its adoption, and outline the uncertainties and challenges involved by usoftax_admin | Sep 25, 2024 | Tax News
Puerto Rico’s Department of the Treasury is looking for public comments regarding possible implementation of the Organization for Economic Cooperation and Development’s 15% global corporate minimum tax on large multinational entities. by usoftax_admin | Sep 25, 2024 | Tax News
Åsa Edesten and Mazlum Yildiz of KPMG Sweden say there remains a lack of clear legal precedent on the impact of ‘control over risk’ in assessing contractual terms between related parties, despite a recent ruling