A Portuguese arbitration court (Tribunal Arbitral) denied the tax authority’s transfer pricing challenge of a multinational’s cash pooling arrangement because its use of the comparable uncontrolled price (CUP) method was inappropriate. The case should alert Portuguese taxpayers to review the arm’s-length nature of their cash pooling arrangements.
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The controversial deal would ‘preserve the gains achieved under pillar two’, the OECD said; in other news, HMRC outlined its approach to dealing with ‘harmful’ tax advisers
TP is a growing priority for West and Central African tax authorities, writes Winnie Maliko, but enforcement remains inconsistent, and data limitations persist
Katie Leah’s arrival marks a significant step in Skadden’s ambition to build a specialised, 10-partner London tax team by 2030, the firm’s European tax head tells ITR
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