The increased diversification of the digitised economy presents a major challenge for BEPS initiatives. Lack of a permanent establishment (PE) had led to debate over where tax should be applied, even where a digital entity is not practising a tax avoidance strategy. The prospect of amended tax legislation to address this has raised concerns over the increased risk of double taxation, and a regulatory burden on multinationals.
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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