The OECD today delivered the second part of its recommendations to reform international tax rules by tackling base erosion and profit shifting (BEPS). While unanimity across all points discussed was impossible, a higher level of agreement - either in the form of consensus or agreement on 'minimum standards' - has been achieved than many expected, though this has not stopped non-governmental organisations (NGOs) from criticising the package as "a sticking-plaster approach".
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Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
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