The US, EU member states and other countries have proposed and/or adopted a limitation rule for the deduction of interest by a corporate taxpayer. Will the OECD try to provide worldwide guidance for interest limitation? Is there an expectation for this guidance in the next several years?
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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
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