In 2004 tax authorities around the world increased their focus on transfer pricing and tax compliance, the European Court of Justice continued to exert pressure on EU member states' tax systems and the US Congress passed significant corporate and international tax reform. Simon Briault gets the views of tax professionals as they peer into their crystal balls for what 2005 has in store.
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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