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.
While pillar two can progress without the US, it won’t reach the same heights without American involvement, argues Renáta Bláhová, founding partner of BMB Partners Taxand
The deal comes after PwC had accused Paul McNab of using confidential information; in other news, McDermott hired a new London tax head from a US rival
Looking at transfer pricing simplification is “obviously helpful”, but it should be done in line with current standards, a senior government figure reportedly said
Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements
Updated rules represent a significant shift in the Luxembourg TP landscape and emphasise the need for robust arm’s-length calculations, says Vanessa Ramos Ferrin of TransFair Pricing Solutions