The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. Michael Lennard, chief of the International Tax Cooperation section of the UN speaks in a personal capacity about some of the issues that may shape transfer pricing arbitration clauses and how they operate in future for taxpayers and their advisers.
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Johanes Glorinus Saragih of Indonesia’s Directorate General of Taxes outlines the nation’s delicate geopolitical situation, as it sits between a rock and a hard place with the US and pillar two
The law firm’s head of tax, trade and wealth management likens tax legislation to a complex puzzle, recommends a sturdy coffee mug, and explains why acronyms make tax cool
Richard Gregg is no longer fit and proper to be a tax agent, said the TPB; in other news, MHA completed its acquisition of Baker Tilly South-East Europe
Recent Indian case law emphasises the importance of economic substance over mere legal form in evaluating tax implications, say authors from Khaitan & Co
As we move into an era of ‘substance over form’, determining the fundamental nature of a particular instrument is key when evaluating the tax implications of selling hybrid securities