Panelists at the April 2011 International Bar Association, International Fiscal Association 11th Annual Tax Planning Strategies, US and Europe conference in Paris discussed a key aspect of the current OECD project on the transfer pricing of intangibles, namely the specification and resolution of the intangible issues that can arise in a business restructuring.
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Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment