Urs Kapalle, head of tax and fiscal policy at the Swiss Bankers Association (SBA) in Basel, and Dominic Gubler, tax counsel at the SBA, look at tax transparency and information sharing initiatives involving Switzerland, assessing FATCA and automatic exchange of information from the Swiss perspective and highlighting the past, present and future activities relating to implementation of the country’s tax transparency strategy.
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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