The OECD has released a draft implementation package that provides for a streamlined withholding tax relief process. This package is likely to be influential in terms of how countries modernise the cross-border withholding tax relief process. It may result in the holy grail of tax relief at source through standardised documentation and electronic filing to be realised.
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The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR
One expert last month predicted the short-term impact of tariffs would be “devastating” for both Canada and the US, particularly if the former instituted retaliatory measures
Audit specialist Walsh, a 33-year veteran of KPMG, will assume the leadership role in July; in other news, a think tank has claimed that the UK tax advisory market requires ‘urgent reform’
The court emphasised that TP analysis must adhere to the arm's-length principle, be based on the specific facts of each transaction and comply with domestic regulations, one expert says