The Australian Tax Office has challenged the transfer pricing practices of BHP Billiton, serving the country’s largest taxpayer with a A$522 million ($432 million) tax bill, based on the pricing of goods it sold to a marketing affiliate in Singapore. The company’s Singapore tax bill is also being questioned under Australia’s controlled foreign company (CFC) rules, which require a minimum payment of tax.
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Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping the GCC’s investment incentive landscape, shifting the region from rate-based competition toward substance-driven economic positioning