Imagine there are 30 adults from all around the world gathered in one room trying to come up with a common way forward on a contentious topic. Each person has his own agenda, a personal interest to protect and wants to get his own way. Now imagine it's your job to draw all these different ideas together and come up with a consensus. That is exactly the gruelling task the OECD has undertaken with its consultation on the transfer pricing aspects of business restructuring.
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Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
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