‘General pause’ on pillar one in many countries: BDO tax chief
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
The need for Indonesia’s industries to adapt to the global minimum tax
Businesses must embrace a new tax paradigm with Indonesia’s adoption of pillar two. Ichwan Sukardi and T Qivi Hady Daholi of RSM Indonesia explore the impact on compliance, transfer pricing, and tax incentives
‘Reinforces crucial principle’: Experts dissect Italian Supreme Court TP ruling
The ruling is ‘well-structured’ in its references to the OECD TP guidelines, one expert says, while another argues it overlooks key technical issues
Indian tax authority signs record 174 APAs in 2024/25
India also brokered its first-ever multilateral APA last year, the Central Board of Taxes announced