It is stating the obvious to say that current international efforts to tackle base erosion and profit shifting (BEPS) have attracted a great deal of global attention. Since the OECD and G20 countries, working together on an equal footing, adopted a 15-point action plan to address BEPS in September 2013, the focus on this issue has steadily grown. David Bradbury, head of the tax policy and statistics division at the OECD Centre for Tax Policy and Administration, and the man overseeing this aspect of the project, provides exclusive insight into an action point that has not always received as much attention as other items in the Action Plan.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires