The effective implementation of the arm’s-length principle is closely linked to the availability of information. In transfer pricing, the asymmetry of information between taxpayers and tax administrations can be acute, potentially opening opportunities for BEPS. For this reason, the BEPS Action Plan stressed the need to enhance transparency in general, and for transfer pricing purposes in particular. Andrew Hickman, Samia Abdelghani and Paul Hondius explain these enhancements in the context of Action 13.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial