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 19, 2024 · Awards. Deloitte leaves ITR’s 2024 EMEA 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. ITR Americas Tax Awards 2024: shortlist announced. ITR is delighted to reveal all …
Conferences | International Tax Review - ITR
WEBApr 25, 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 …
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.
Global - International Tax Review
WEB4 days ago · Overall, 2023 saw the world of tax seek to solidify common standards via a significant legislative overhaul. Oleg Rak, managing partner of specialist tax recruitment firm Mason Rak, analyses current trends from the year, and what they mean for tax leaders looking to gain an advantage in a competitive market
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.
A new age of country-by-country tax transparency in the financial ...
WEBAug 27, 2024 · The past decade has seen a continuous push for increased levels of tax transparency for multinational enterprises (MNEs). Large MNEs have provided revenue authorities with an OECD country-by-country report (CbC Report) for some seven years, with revenue authorities using CbC Reports and other transfer pricing documentation (in the form of local files and master files) to assess potential BEPS ...
Deloitte Transfer Pricing Controversy guide | International Tax …
WEBSep 27, 2023 · The shifting tides of TP: a closer look at tax controversy driving legislative changes. Christine Ramsay and Samer Wani of Deloitte Canada and Subhabrata Dasgupta of Deloitte Malaysia highlight significant legislative developments in several jurisdictions as the world strives to keep pace with the OECD's Transfer Pricing Guidelines.
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 ...
Brazil: Understanding the Tax on Financial Operations (IOF) - ITR
WEBSep 5, 2012 · As the Financial Times has already stated, Brazil "is one of the fabled fast-growing BRIC economies – Brazil, Russia, India and China – that are reshaping the international order. And as the host of the next football World Cup and, in 2016, the Olympic Games, Brazil has confidently arrived on the global stage". This economic and political progress is driving foreign investment in the country.
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