Taxpayers should not overlook the hidden tools in the MAP toolbox when it comes to dispute resolution, particularly supplementary dispute resolution (SDR). Here Emile Simpson and Peter Nias write about the routes open to businesses.
This week Barclays’ tax affairs came under scrutiny after claims the bank avoided paying UK corporate tax via a Luxembourg structure, while the European Commission put forward its long-awaited proposal for an equity tax incentive.
Eric Lesprit, Mariusz Każuch and Howard Osawa look at three national case studies and consider whether the increased use of international data improves cooperation among tax administrations.
Kerwin Chung and Iva Georgijew assess the impact of the coronavirus pandemic on global transfer pricing and consider how the concept of the arm’s-length principle will subsequently evolve.
Mo Malhotra, Ariel Krinshpun and Ockie Olivier evaluate how the OECD guidance on financial transactions will influence an increasingly convoluted transfer pricing environment.
