A recent decision by the Danish Tax Tribunal showed that benchmark analysis with comparable parties is one of the most important elements to be included in transfer pricing documentation in order to avoid taxable income adjustments.
The UK will need to decide on its approach to taxing the digital economy after Brexit. Adopting potential laws from the upcoming EU Commission’s digital tax proposal is one option, but implementing unilateral measures is also on the cards.
The Australian Taxation Office continues to seek closer engagement with large taxpayers as it releases guidelines for multinational companies to assess the risk of their related-party debt financing.
Cyber security is among the top concerns for taxpayers and tax authorities as country-by-country reporting is being rolled out in more than 40 countries. Some tax directors are now considering to think of the CbC report as a potentially public document in case of hacks or leaks.
The EU and the OECD are both setting out proposals for how to best tax companies in the digital economy. While EU sources say the two proposals could be similar, the OECD is worried doubling up could obstruct a harmonised approach to digital taxation.
Corporates in the UK may see unexpectedly large bills if they are hit with a diverted profits tax charge, as the legislation does not grandfather pre-existing arrangements.
