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 ...
Home | International Tax Review
WEBSep 13, 2024 · International Tax Review is a leading source of news, analysis and awards for the global tax industry. Find out the latest developments on transfer pricing, indirect tax, ethics, disputes, rankings and more.
Managing a company's effective tax rate | International Tax Review …
WEBApr 30, 2008 · Adrian Windsor and Jeremy Curd, of PricewaterhouseCoopers in the UK, discuss the value of managing a company's effective tax rate. The effective tax rate (ETR) is probably the most common measure of corporate income tax. It is also the most common internal target metric set for the tax department. However, the …
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.
2019 Asia Tax Awards: The winners | International Tax Review - ITR
WEBMay 28, 2019 · The winners of International Tax Review’s 2019 Asia Tax Awards have been announced. Professional services firm EY was awarded Asia Tax Firm of the Year, with KPMG crowned as Asia's Transfer Pricing and Disputes and Litigation Firm of the Year. A total of 18 jurisdictions were celebrated in ITR 's national, regional and leader awards at a ...
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.
Case study: Determining the benefits of profit splits
WEBOct 24, 2019 · Determining the benefits of profit splits. The European consumer goods company decided to use the profit split method after carefully weighing up the pros and cons of each TP method. The profit split method had to meet a series of standards to become the main method for certain transactions. …
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 …
World TP 2021 is live: A guide to the world's leading transfer …
WEBSep 30, 2020 · Produced in association with ITR (International Tax Review), World TP provides rankings and profiles of the most effective transfer pricing practitioners in the world, covering more than 60 jurisdictions located on every continent.
ITR Awards | International Tax Review
WEBApr 25, 2022 · ITR EMEA Tax Awards 2024: shortlist announced. ITR is delighted to reveal all the shortlisted nominees for the 2024 Europe Middle East & Africa Tax Awards. John Harrison, July 25, 2024. Awards.