Indonesia: Updates on DTAs with the Netherlands, Malaysia, and …
Oct 2, 2017 · Indonesia's protocol to its agreement with the Netherlands for the avoidance of double taxation (DTA) is effective from October 1 2017. The Indonesian President issued Presidential Regulation No. 24 of 2017 on March 9 2017 to ratify the protocol to the DTA, signed in Jakarta on July 30 2015 (PR No. 24/2017), which amends the DTA signed on January 29 2002 in …
A brave new world in tax transparency: CRS in China, Hong Kong …
November 28, 2017. Increasing cross-border business and investment has made the holding of assets overseas through offshore accounts increasingly common. This has become a new tax battleground for businesses and governments. Charles Kinsley, Henry Wong, and Eva Chow look at the latest developments regarding these efforts in China, Hong Kong and ...
IP transfers: Tax and accounting considerations
Dec 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.
ITR Awards | International Tax Review
Jul 25, 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.
Five minutes with…Peter Roscoe, RCK Partners
Oct 10, 2024 · Since becoming a father, my daily routine has changed considerably. I used to arrive at the office at 8.30am and work through to 7pm, but now I usually arrive later so I can spend time with my son in the morning – though today he was up at 4:30am, so I got a few more hours with him than expected. I’m sure most parents can empathise!
ITR Americas Awards 2024 Winners Hub | International Tax Review
ITR celebrated the achievements of the financial law community in Americas with a dinner in New York on September 26.
Treatment of forex gains and losses in transfer pricing
Aug 22, 2012 · Any unheralded deviation from the projected rate could result in a loss or gain situation. An enterprise has little or no control on this loss or gain; therefore it may be termed as an unplanned result if Forex risks are not fully hedged. In transfer pricing, whether forex gain or loss is to be treated as an operating income or loss is an issue.
Inside global tax functions | International Tax Review - ITR
Jan 24, 2024 · KPMG International’s Global Tax Function Benchmarking Survey charts the evolution of leading tax functions and identifies operational benchmarks for high-performing tax teams. The selected findings in this summary report are based on a survey of almost 200 leaders in charge of tax policy and operations of companies in all major sectors, with ...
This month in indirect tax: VAT rates edge up after economic …
Oct 2, 2024 · The UK government announced on September 23 that it would soon launch a consultation on electronic invoicing, or e-invoicing, to promote its wider use across UK businesses and government departments.. A significant reduction in administrative tasks, improved cash flow, a boost to productivity, more automation, a reduction in errors in tax returns and help in closing the tax gap are seen as ...
Maquiladoras’ TP compliance after the 2022 Mexican tax reform
Sep 27, 2023 · The 2022 tax reform eliminated the APA as a compliance option for maquiladoras, leaving the safe harbour as the only framework for a maquiladora to comply with TP requirements and maintain the benefits of this operating structure for income tax purposes. Only the taxpayers with an APA ruling in force or an APA programme in progress may still use the APA until its expiry, which in all cases ...