While GAAR are new in China taxation, they have made great waves in the past couple of years. The controversial Circular 698 on indirect disposals will be here to stay in one form or another, but not without increasing resistance from foreign corporations and tax administrations. John Gu, Chris Xing and William Zhang of KPMG expect that the SAT may have to provide clearer guidance and explore an advance ruling system as a way to address the concerns of taxpayers.
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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
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
The boutique Australian firm’s TP award recognition proves that world-class advisory services aren’t limited to the ‘big four’, the firm’s founder tells ITR
Canadian and Indian dual VAT models have been a source of inspiration for the Brazilian model, but the latter has unique and innovative features, the OECD paper claimed