Outside expertise will allow the UK tax authorities to attack transactions they view as risky with a whole new level of sophistication, says Ted Keen of the Ballentine Barbera Group, a CRA International company. UK taxpayers who have not yet done so should revisit their transfer pricing documentation, particularly where transfers of valuable intangible property are concerned
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems