The 2013 Action Plan on Base Erosion and Profit Shifting (the BEPS Action Plan) identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. Jacques Sasseville and Edward Barret look at the work done to counter the unintended uses of tax treaties in an international context.
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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