Understanding the beneficial ownership v. beneficial holding …
WEBSep 14, 2021 · The concept of ‘beneficial ownership’ is found under the international tax treaties. The tax treaties are negotiated based on the model tax conventions and these conventions inter alia provide explanations as to the intent and purpose behind terms appearing therein. The phrase ‘beneficial owner’ appears in both the OECD Model Tax Convention and the UN Model Tax Convention in the ...
ITR Awards | International Tax Review
WEBSep 27, 2024 · Deloitte leaves ITR’s 2024 Awards as biggest winner. The firm picked up awards for its work in multiple jurisdictions, while DLA Piper walked away with four individual honours. Sam Sholli, September 19, 2024. Awards.
Transfer Pricing | International Tax Review
WEBSam Sholli, September 19, 2024. Transfer Pricing. Transfer Pricing Forum 2024: Financial transaction audits ramping up. On a panel of advisers and tax authority representatives from a range of European jurisdictions, financial transactions were pinpointed as a key TP audit focus. Tom Baker, September 18, 2024.
Tax technology: a powerful ally in the race against regulation
WEBJan 2, 2024 · The future of tax technology. The future of tax technology is promising. Advancements in AI, machine learning, and robotic process automation (RPA) are revolutionising tax compliance. AI-powered tax software can automatically categorise and analyse transactions, identify tax-related issues, and even predict regulatory changes.
Conferences | International Tax Review - ITR
WEBSep 26, 2024 · ITR produces 8 high-level conferences and summits a year which attract over 1,000 attendees. For more information, contact: Jamil Ahad, Commercial Director. [email protected]. +44 (0) 207 779 8767. Jamil heads up business development for ITR events. He helps firms network, engage and do business with tax and TP leaders from ...
IP transfers: Tax and accounting considerations
WEBDec 17, 2012 · Royalties paid in exchange for the right to use or exploit IP outside of the US are typically foreign-source income – IRC §862(a)(4). In contrast, the gain from the sale of IP – patents, copyrights, secret processes or formulas, goodwill, trademark, trade brand, franchise, or other like property – is generally sourced under IRC §865 according to the residence of the seller.
The long expected Brazilian tax reform – objectives, challenges and ...
WEBMar 30, 2020 · The Brazilian government and the Congress began 2020 by reiterating that reforming the tax system is one of the main priorities and that the initial objective is to consolidate the different propositions into a single project, which would follow the legislative process within the House of Representatives and the Senate.
ITR World Tax rankings released: global firms dominate
WEBAug 21, 2024 · The World Tax rankings encompass over 155 jurisdictions and more than 5,100 firms worldwide. These firms were assessed for their competencies across a range of tax areas, including transactional tax, tax controversy, transfer pricing and indirect tax. The ITR editorial team does not compile the rankings, but we sat down with World Tax’s ...
Plastic taxes: a guide to new legislation in Europe
WEBFeb 15, 2023 · The tax rates are €450 (~$465) per ton of taxable plastic in Spain and Italy, and £200 (~$250) per ton in the UK. The expected (net) government revenue from the Italian plastic tax was estimated to be almost €470 million (~$484 million) for the first year, and from the Spanish plastic tax, €724 million ($745) million.
MLI: Testing the ‘principal purpose’ | International Tax Review
WEBDec 12, 2018 · The MLI essentially allows the tax treaty-related measures of the OECD/G20 BEPS project to be introduced into the existing tax treaties of the signatories to the convention in a consistent and efficient manner, eliminating the need to renegotiate every bilateral tax agreement separately. The MLI positions adopted by each participating ...