The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. Michael Lennard, chief of the International Tax Cooperation section of the UN speaks in a personal capacity about some of the issues that may shape transfer pricing arbitration clauses and how they operate in future for taxpayers and their advisers.
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The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
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