The 2013 BEPS Action Plan recognised that “actions to counter BEPS must be complemented with actions that ensure certainty and predictability for business”. Edward Barret and Evelyn Lio track the work of Action 14 of the BEPS Action Plan, which called for work to improve the effectiveness of the mutual agreement procedure (MAP) and thereby address obstacles that currently prevent countries from solving treaty-related disputes and minimise as much as possible elements of uncertainty related to the interpretation and application of novel rules resulting from the other work on BEPS issues.
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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