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"Thanks... Good Talk" Shortcast

Ivan Zapien focuses his shortcast on the issues, people, and culture that help shape Washington, D.C.

Insights and Analysis

Doing business in Italy 2023

In Italy, there are special requirements which apply to specific types of companies (for instance investment, insurance, and banking companies and companies whose shares are traded on a...


Mexico | Taxation and Collection Master Plan for 2023

The Tax Administration Service published the coordination strategy for taxpayer audits for the fiscal year 2023, which mainly consists of management by the tax authority for taxpayer...


Applying an arm’s length comparator to intra-group debt: the role of third-party covenants

When applying the UK’s transfer pricing rules to compare an intra-group loan to the hypothetical arm’s length transaction that an independent third-party lender would have...


UK government plans to introduce a re-domiciliation regime

On 27 October 2021, HM Treasury, BEIS and HMRC published a consultation paper seeking views on proposals for a UK re-domiciliation regime under which foreign-incorporated companies could...


HMRC’s PDCF campaign continues – back to business

HMRC have announced that it will be holding a webinar on Tuesday 6 October to provide an update on its Profit Diversion Compliance Facility (PDCF). The facility is a mechanism...

Insights and Analysis

Double standards for the taxation of intra group financing

The German Federal Ministry of Finance has published a draft law for the implementation of the EU Anti-Tax Avoidance Directive (ATAD Implementation Act) on 10 December 2019. This draft...

Insights and Analysis

Coronavirus (COVID-19) - Summary of key international tax measures

Taxpayer-friendly changes in tax law are fast becoming key weapons in governments’ arsenals for tackling the economic fallout of COVID-19.


COVID-19: International Taxation – a View from OECD

The Covid-19 lockdown measures may result in adverse effects on the right to tax between countries which is currently provided for in international tax treaties.

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