Imagine there are 30 adults from all around the world gathered in one room trying to come up with a common way forward on a contentious topic. Each person has his own agenda, a personal interest to protect and wants to get his own way. Now imagine it's your job to draw all these different ideas together and come up with a consensus. That is exactly the gruelling task the OECD has undertaken with its consultation on the transfer pricing aspects of business restructuring.
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The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR