Austria

Hendrik Blankenstein, Tom Lawson and Caterina Colling Russo of Tax Partner AG – Taxand Switzerland present a comparative study on how the OECD’s guidance on financial transactions will impact the characterisation and pricing of inter-company loans for MNEs in Switzerland.

Indonesia has strengthened its tax disputes framework by adapting a more sophisticated procedure when handling advance pricing agreements (APAs) and mutual agreement procedures (MAPs). Charles Setia Oetomo and Felic Setiawan of GNV Consulting Services examine how the developments are an attractive premise for businesses in the region.

Cyril Maucour and Jessica Benchetrit of DS Avocats evaluate the effectiveness of the OECD’s new unified approach, which provides market jurisdictions greater taxing rights over residual profits.