Tax transparency is a cornerstone of the global tax agenda and it is now at a critical moment as the universal policy consensus moves to global implementation. Achim Pross, Philip Kerfs, Paul Hondius of the OECD and Radhanath Housden of the Global Forum take stock of the progress made so far on offshore tax evasion, country-by-country reporting (CbCR) and the exchange of information on tax rulings and provide insights into the steps ahead.
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Under the merged scheme for R&D tax relief introduced last year, rules on contracted out R&D have changed. James Dudbridge argues for a proactive approach when reviewing companies’ commercial arrangements
Updated rules represent a significant shift in the Luxembourg TP landscape and emphasise the need for robust arm’s-length calculations, says Vanessa Ramos Ferrin of TransFair Pricing Solutions
Wopke Hoekstra also swore the EU would ‘hit back harder’ if faced with a trade war; in other news, a UK watchdog has launched an investigation into an audit completed by MHA
A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland