The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. In this three-part series, 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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While pillar two can progress without the US, it won’t reach the same heights without American involvement, argues Renáta Bláhová, founding partner of BMB Partners Taxand
The deal comes after PwC had accused Paul McNab of using confidential information; in other news, McDermott hired a new London tax head from a US rival
Looking at transfer pricing simplification is “obviously helpful”, but it should be done in line with current standards, a senior government figure reportedly said
Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements
Updated rules represent a significant shift in the Luxembourg TP landscape and emphasise the need for robust arm’s-length calculations, says Vanessa Ramos Ferrin of TransFair Pricing Solutions