Sandy Bhogal, head of tax at Mayer Brown in London, outlines where we stand with respect to recent multilateral work to counter base erosion and profit shifting (BEPS) and, specifically, Action 4 of the OECD Action Plan, after first pausing to reflect on how and why we got to this point. Conceptually, Action 4 sought to consider ways to reduce base erosion that can occur through interest payments and other economically equivalent amounts.
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The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions