If one country has been a trailblazer in using the tax system to attract investment, it is Switzerland. But against a backdrop of international reforms and pan-European harmonisation, the scope for challenge of national regimes is increasing. Compliance initiatives such as the US FATCA, and the way it has been imposed on financial institutions and tax authorities around the world, highlight that outliers will no longer be tolerated. With this in mind, the 3rd edition of ITR's Swiss Focus brings you the latest domestic developments and analysis of how multilateral reforms are impacting taxpayers in Switzerland.
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
