With the release of the OECD’s final package of recommendations to tackle base erosion and profit shifting (BEPS), the focus now shifts to the manner in which national authorities take up, and implement, the measures outlined. Country-by-country reporting (CbCR) implementation has already begun in a number of countries, including Germany, and use of the reporting method is set to be expanded next year.
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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
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting