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  • The BEPS Action Plan and its impact on global transfer pricing principles

    The OECD's Action Plan for tackling base erosion and profit shifting (BEPS) was unveiled on July 19 at the G20 meeting of finance ministers in Moscow. The plan discusses a timeframe of between 12 and 24 months for implementing action and outlines how the OECD will work with national states to improve the overall tax take and clamp down on tax arbitrage by addressing perceived flaws in international rules. The plan specifically references transfer pricing and Sophie Ashley discusses its impact on global principles and how taxpayers can expect them to change.


  • Article 8 of the OECD Model lags behind international business

    Anne Jorritsma and Marlies Baijer of KPMG in the Netherlands argue that ambiguity in Article 8 of the OECD model treaty means that it no longer follows how the business of international maritime traffic operates.

  • Multistate US tax issues for inbound companies

    Foreign companies with activity in the US are often surprised that such activity may trigger both federal and state-level tax implications. Joel Walters, Maureen Pechacek and Todd Roberts of PwC US explore how state tax exposure may vary substantially, potentially resulting in significant state tax liabilities even when little to no US federal tax obligations exist.

  • BRICs attracting investment despite their tax systems

    While many countries, such as the UK, actively try to attract investment by promoting an open for business agenda epitomised by offering attractive tax benefits such as a competitive corporate income tax rate and a patent box scheme, the BRICs countries – and Brazil in particular – are managing to attract investment in spite of their unattractive and complex tax regimes. Matthew Gilleard finds out why.

  • UN Manual – India chapter: A tale of the existing TP impasse

    The United Nations (UN) has released the final version of the Practical Manual on Transfer Pricing for Developing Countries (the UN Manual). Vatika Bhatnagar, of Airtel India Limited, examines the Manual’s India chapter, which covers the key issues faced by taxpayers in the country.

  • Why India has become the boy who cried wolf

    India’s Ministry of Finance has been upping its efforts to lure foreign investors by reassuring them the country’s tax regime is not unfairly targeting foreign multinationals. It is even going to the trouble of holding a weekly audience for taxpayers. But have multinationals heard this all before? Joe Dalton discovers why tax directors remain wary when they hear the Indian government make tax promises, and what measures might restore their confidence.

  • Achieving the G8’s aims on beneficial ownership

    At the G8 summit in Northern Ireland in July leaders committed to a common set of principles that would limit profit shifting and increase tax transparency. Emma Powell looks at how achievable these aims are and what impact they will have on businesses.

  • Special features - September 2013

    Read this month's special features on Brazil and Asia.

  • LVCR: Evasion, avoidance or abuse?

    In part one of a two-part series, Richard Allen of Retailers Against VAT Avoidance Schemes (RAVAS) explores the avoidance debate in relation to low value consignment relief (LVCR), VAT and the offshore fulfilment industry.

  • No escape: Businesses cannot ignore indirect tax

    In 1969, 10 countries imposed some type of indirect tax. Today, indirect tax is prolific. More than 160 countries have, plan to have, or are considering some form of indirect tax. Gary Harley, head of indirect tax at KPMG in the UK, explores the rise of indirect taxation.

  • Enforcing foreign tax debts: How far back can you go?

    Matthew Greene, a solicitor at PwC Legal in London, looks at what a recent UK Court of Appeal decision can tell taxpayers about the courts’ approach to interpreting tax treaty provisions.

  • How to manage an ATO audit

    Under Australia’s self assessment tax system, effective tax risk management is critical in minimising the likelihood of a tax audit and maximising the chances of a favourable outcome from the ensuing investigation. Paul Sokolowski and Clint Harding, of Arnold Bloch Leibler, explain how taxpayers should manage an Australian Taxation Office (ATO) audit to give themselves the best chance of a positive outcome.

News Analysis


Tax Relief

  • Tax Relief

    A monthly commentary on the notable facts, figures and goings-on in the tax world.

International Correspondents

International Correspondents