There have been a number of significant developments in the area of US tax controversies during 2016. Fenwick & West highlight some of the top US tax cases from this year, including several large § 482 transfer pricing cases that could provide helpful insight for taxpayers who may be facing similar significant transfer pricing adjustments.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights “significant concerns”
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance