The OECD today delivered the second part of its recommendations to reform international tax rules by tackling base erosion and profit shifting (BEPS). While unanimity across all points discussed was impossible, a higher level of agreement - either in the form of consensus or agreement on 'minimum standards' - has been achieved than many expected, though this has not stopped non-governmental organisations (NGOs) from criticising the package as "a sticking-plaster approach".
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements
HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented
Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed
In the second instalment of this two-part series, Jayne Stokes takes a practical approach to navigating the capital v revenue question for UK R&D claims for software development, and shares pointers for businesses
ITR's latest podcast considers how transformational the buyout could be in Ryan's quest for global advisory reach and analyses a recent boom in demand for private client advisory services