The CCCTB concept of relies on formulary apportionment, doing away with the arm’s-length principle (ALP). While many people welcome the opportunity to debate the future of tax compliance, others feel a switch to formulary apportionment will create just as many problems as the ALP. Sophie Ashley talks to the CCCTB’s critics and supporters about its impact on transfer pricing.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
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
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment