The Council of the European Union has acted on BEPS Action 2 after adopting a directive to clamp down on the use of hybrid mismatch arrangements and halt corporate tax avoidance, but this could result in uncertainty for businesses.
Good news for businesses, which could see lower compliance costs after the EU Economic and Financial Affairs Council (ECOFIN) this week agreed on a new system for resolving double taxation disputes for its 27 member states.
Chevron has announced it will appeal its A$300 million ($226 million) tax bill after its Federal Court loss last month, but with the Australian Taxation Office (ATO) setting its sights on at least a dozen high-risk companies for similar arrangements, things are not looking up for corporates.
Mexican firm Creel, Garcia-Cuellar, Aiza y Enriquez now offers transfer pricing services, and has hired Laura Frias as TP counsel, as well as a team of specialised associates.