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News and Analysis

  • Embracing tax certainty through improved dispute resolution

    December 14, 2017

    A suite of mutually reinforcing measures with an overall focus on resolution at the earliest point in time is the ultimate goal for taxpayers and tax authorities. Achim Pross, Sandra Knaepen and Mark Johnson of the OECD describe the organisation’s comprehensive dispute resolution agenda, both within and beyond the BEPS project.

  • EU holding company structure in treaty shopping cases

    August 23, 2017

    The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.

  • Welcome to the world of secondary adjustments

    February 28, 2017

    Tirthesh Bagadiya of Bagadiya & Jain looks at what he sees as the beginning of a new era in Indian transfer pricing regulations

International Correspondents