The 2013 Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan) identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Jacques Sasseville and Edward Barret look at the work done to counter the unintended uses of tax treaties in an international context.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners
Sweeping changes are headed for Germany’s TP system in the New Year. Tax teams will need to be well-prepared, say Andreas Katz and Anna Kupprion of Kreston Bansbach