Sandy Bhogal, head of tax at Mayer Brown in London, outlines where we stand with respect to recent multilateral work to counter base erosion and profit shifting (BEPS) and, specifically, Action 4 of the OECD Action Plan, after first pausing to reflect on how and why we got to this point. Conceptually, Action 4 sought to consider ways to reduce base erosion that can occur through interest payments and other economically equivalent amounts.
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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