There has been a significant rise in controversy around the world in recent years centred on the topic of the beneficial owner test which appears in the dividends, interest and royalties articles of most double tax treaties. Richard Collier, of PwC, explores the work of the OECD in this area to date and what the future holds, calling for greater clarity on the concept.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
As World Tax unveils its much-anticipated rankings for 2026, we focus on standout performances by PwC, KPMG and Deloitte across the Asia-Pacific region
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off