Are new laws incapable of being subject to statutory construction to depict their meaning? Or are such laws so poorly drafted that companies must glean their intended meaning, outside the parameters of the legislated verbiage, from conference reports, statements of intent by tax authorities at international conferences and referencing documents?
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The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
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