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  • Chuck Hurley will join Norton Rose Fulbright in its Washington DC office as a partner.
  • Wendy Martin has extended her role as partner at EY's Channel Islands office. She will take over as head of tax for the firm, replacing Peter Willey who has returned to EY's UK team.
  • India and Mauritius have signed a protocol that amends certain measures in their Double Tax Agreement (DTA), which will help to prevent tax avoidance as part of the India Government’s efforts to tackle BEPS.
  • The Supreme Court in Delhi has accepted an appeal from the Income Tax Department (ITAT) against a Bombay high court order, which rejected the ITAT’s transfer pricing adjustment for the sale of one of its call centres in 2007.
  • BEPS aims to prevent aggressive profit-shifting strategies to better align transfer pricing outcomes with value creation. In this paper, Dale Hill, a partner at Gowling WLG, examines BEPS’s application to the transfer pricing aspects of intangibles and the impact on tax-motivated IP migration strategies.
  • The Internal Revenue Service appears to be strengthening its stand on aggregating transactions and applying economic substance rationales to override related-party contracts. David Forst and Larissa Neumann of Fenwick & West discuss US developments including the IRS and Treasury Department-issued 482 Temporary Regulations.
  • The framework for analysing intercompany transactions involving intangibles is examined by Hendrik Blankenstein and Caterina Colling Russo at Tax Partner AG – Taxand Switzerland. Does the new DEMPE analysis benefit MNEs and tax authorities or simply confuse matters, resulting in an increase of intangibles-related disputes?
  • Much lies beneath the surface of BEPS. How will BEPS affect Korean multinationals and what do MNEs need to learn? Tae Hyung Kim, partner and senior transfer pricing economist at Deloitte Korea, explains exactly what multinationals must consider and what they should fear.
  • The boldest initiative in transfer pricing history entered the homestretch in October 2015 with the release of the OECD's final report on its base erosion and profit shifting (BEPS) project. The reverberations are being felt across North America, Europe, Asia and beyond.
  • Alfredo Sánchez Torrado and Eduardo García Ruiz examine the way in which investments are currently structured in Mexico via private equity funds, the application of treaty benefits by them, as well as how BEPS Action 6 may affect such application.
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