While the OECD has political backing and momentum behind it, the organisation has no binding authority to implement legislation, so the engagement of key jurisdictions including the US will be central to the project's ultimate success. Ryan Dudley, partner at Friedman, explains why the hard yards still lie ahead.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems