On November 5 the US-based International Consortium of Investigate Journalists (ICIJ) released the tax rulings of 548 corporations accused of having ‘secret tax agreements’ with Luxembourg. A follow-up piece in the Australian Financial Review went as far as to accuse the Big 4 of facilitating the agreements in an article titled ‘Big four audit firms behind global profit shifting’.
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Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment