On November 5 the US-based International Consortium of Investigate Journalists (ICIJ) released the tax rulings of 548 corporations accused of having ‘secret tax agreements’ with Luxembourg. A follow-up piece in the Australian Financial Review went as far as to accuse the Big 4 of facilitating the agreements in an article titled ‘Big four audit firms behind global profit shifting’.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems