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
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The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions