ITR Voices

In the second edition of ITR's new monthly podcast series, ITR Editor Tom Baker and Senior Reporter Sam Sholli dive into all the controversies and nuances of the US/OECD side-by-side arrangement on pillar two. 

From a clash of ideas between two tax policy heavyweights to Brazilian businesses citing implementation struggles, the ITR editorial team covers all the ground from a dramatic period for the carve-out deal. 

Also on the agenda: bespoke ITR research which suggests that gender equality in the tax profession has improved "significantly", and a dissection of the AI strategies of the big four accountancy firms. 

We hope you enjoy listening. 

ITR is excited to announce the launch of a new monthly podcast series, Taxing Times with ITR, with the first episode available to listen to now.

Hosted by ITR Editor Tom Baker and Senior Reporter Sam Sholli, the series will act as a monthly digest of the biggest and most interesting tax stories from the preceding few weeks as well as a preview of the big issues ahead. 

As well as analysing recent developments and previewing future stories, the ITR editorial team will offer behind-the-scenes insights into how such articles are researched and crafted. 

In our first edition, Tom and Sam analyse Deloitte’s €20 billion EMEA merger and US President Donald Trump’s tariff defeat at the US Supreme Court.

Also on the agenda: the evolution of Venezuela’s tax regime following the deposition of Nicolás Maduro, and exclusive ITR data which reveals that diversity, equity and inclusion policies are not influencing clients’ buying decisions in the US. 

We hope you enjoy listening.

How are transfer pricing audits evolving under heightened scrutiny in Europe? In this ITR podcast, held in collaboration with CMS, three experts from the firm’s European offices – Vittoria Segre, Mohamed Haj Taieb, and Andréa Rizk – discuss the latest trends, challenges, and strategies for multinational enterprises.

From robust documentation and valuation of intangible assets to coordinating with HR and leveraging AI, the discussion highlights how multinational enterprises can mitigate risk and navigate complex audits. Tune in for insights on advance pricing agreements, the OECD’s amount B, and the proactive steps businesses can take to stay ahead of red flags in transfer pricing.

How are AI, automation, and global economic pressures transforming the way tax disputes unfold? In this ITR podcast, held in collaboration with CMS, four expert practitioners from the UK, Sweden, Italy, and Brazil explore the new realities of audits, litigation, and compliance.

As tax authorities deploy advanced technology to boost efficiency and revenue, taxpayers must adapt – strengthening documentation, managing risk proactively, and considering settlement where appropriate. Tune in for an international perspective on the trends, tools, and strategies shaping the future of tax controversy and dispute resolution.

Deloitte Global leaders Chad Hungerford and Chris Oates reveal the key practical challenges of pillar two implementation while finding cause for optimism and even excitement in an exclusive podcast with ITR.

What motivates tax professionals to get up in the morning, and what keeps them up at night? Hungerford and Oates provide their insights in this wide-ranging podcast. The guest speakers draw on recent experience with tax authorities and clients to provide an inside track on the rapidly evolving pillar two landscape, with the significance of this moment resonating powerfully.

“Whilst this is a challenge,” Oates tells ITR commercial editor Phil Myers, “if you flip the coin, this is probably the most interesting new bit of tax legislation that has been introduced in my lifetime from a corporate perspective. And we see that reflected when we’re having conversations.”

The podcast explores the following areas:

• Emerging issues uncovered – Chad and Chris delve into the hurdles companies are finding;
• Priorities for companies – where businesses should be placing their focus at present;
• Common misconceptions – correcting widespread misunderstandings;
• M&A and growth plans – why pillar two must be factored in;
• Safe harbours and their future – why tax practitioners should “prepare for the worst and hope for the best”;
• Varying jurisdictional approaches – the “different flavours of implementation”;
• Technology transitions – whether now really is the right time to be considering new solutions; and
• The outlook – where is pillar two heading?

While the complexities and technicalities are addressed, the podcast also brings out the passion and excitement that drives tax professionals to tackle these challenges. The insights and practical advice on offer could help to arm you with the knowledge to navigate what, we are warned, could be a bumpy road ahead. As Hungerford says, “This is not something you can minor in – that you can spend a lot of time in every other area of tax and then just dabble with pillar two.”

Listen in and dive deeper into pillar two.

Dhruva tax experts Mehul Bheda, Kulraj Ashpnani and Ashish Agrawal review a whirlwind year for tax in India, in an exclusive podcast with ITR

It was a transformative year for tax in India, as 2023 saw a host of highly anticipated Supreme Court decisions and government policies impact the way both domestic and multinational companies do business. 

To help navigate this dynamic period, ITR editor Tom Baker spoke with three experts from Dhruva Advisors, partners Mehul Bheda and Kulraj Ashpnani and associate partner Ashish Agrawal, in an in-depth and colourful fireside chat. 

First on the agenda was analysing the fallout from a 2022 Supreme Court ruling related to the taxation of secondees from multinational groups to Indian entities. The speakers highlighted that multinationals need to be careful in the underlying documentation of expat secondment arrangements.   

Next, Agrawal reviewed a Supreme Court ruling from October 2023 regarding most favoured nation (MFN) clauses with India. The ruling stated that specific notifications by the Indian government was mandatory to invoke the MFN clause in India’s tax treaties. 

Agrawal warned of the implications: "[The Supreme Court ruling on most favoured nation clauses] could have severe implications for Indian companies and overseas taxpayers especially for past transactions, and the government needs to deal with it in a more pragmatic way."

Bheda then chimed in with a summary of recent case law regarding the buyback of company shares and the ensuing dividend tax considerations, before discussing changes to India’s ‘angel tax’ rules.

"The 'angel tax' is very peculiar. If you issue shares at a premium, they have to conform with 'fair valuation rules'”, Bheda argued. 

“If the share premium is in excess of fair value, the excess will be treated as income and taxed accordingly. It's a very punitive provision. There is nothing 'angel' about it!"

The session concluded with all participants attempting some crystal ball-gazing, and predicting what new tax controversies will arise in 2024, a crucial election year in India. 

About Dhruva 

Dhruva is dedicated to setting industry standards through exceptional service delivery. With strategic prowess, Dhruva has successfully managed numerous substantial and pivotal tax disputes and related matters within India.

Dhruva’s esteemed team includes 15 partners, five senior advisors, 11 associate partners, 30 principals, and over 300 exceptionally talented professionals.

Peter Olanday, director of consulting for vertical solutions at Vertex, talks to Alice Jones about using edge computing to manage real-time tax calculation as omnichannel shopping becomes increasingly common.

In this awards special edition of Tax Insights podcasts, ITR’s Commercial Editor Prin Shasiharan is joined by experts Chuck Kosal, Jennifer Deutsch and Kristine Riisberg of Deloitte.

In September 2021, Deloitte retained its title as the Americas Transfer Pricing Firm of the Year by ITR, while also achieving widespread national and regional success throughout the Americas across a number of categories including Tax Innovation and Tax Technology. The winners were announced in a virtual ceremony attended by several of the region's leading in-house and private practice tax professionals.

The experts discuss how Deloitte has stayed ahead of competition amid the challenges of doing business during the pandemic, outlining the importance of tax technology and innovation through practical examples.

This includes further insight into its strong pan-American regional network, its transformation strategy, and its accountability to clients.

Innovative compliance tools. New approach to reporting. Smart tech. ITR Asia-Pacific Tax Awards winners Jenny Clarke and Cristina Alvarez discuss how the team at KPMG is ‘re-imagining’ tax in the region.

In this awards’ special edition of Tax Insights podcasts, ITR’s Prin Shasiharan is joined by two KPMG leaders working in the Asia-Pacific region.

In August 2021, KPMG was announced as the Asia-Pacific Compliance and Reporting Firm of the Year by ITR, while also achieving widespread national and regional success throughout the region across a number of categories. The recognition marked the firm’s fourth consecutive triumph in the category.

The experts discuss how tax compliance has evolved over the last decade, including the impact of the KPMG’s renowned ‘Tax Reimagined’ offering, and the big picture challenges that multinational organisations face as they look to transform their tax functions. They provide examples of successful projects and provide advice for business leaders contemplating evolving their tax operations.