The battle to stop the abuse of tax havens is becoming widespread. The Ecuador Tax Administration is joining the fight, using strategies such as making it impossible for companies whose shareholders are located in tax havens to participate in public procurement, charging additional taxes on dividends and presuming related-party relationships between transacting parties, which can have effects on transfer pricing.
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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