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.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies