Almost universally in 2012, it seems there has been a pledge from revenue authorities bidding to spare resources, and taxpayers craving certainty, to try and reduce the risk of entering new litigation. But while some litigation is undoubtedly avoidable, there are always those cases which climb through the judicial system, demanding attention from the highest courts. Such cases often have a dramatic impact on how taxpayers do business. Joe Dalton looks at the tax rulings multinationals need to follow in 2013.
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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
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