The concept of a principal company structure (PCS) is far from new, yet national tax regimes are increasingly targeting these structures for enhanced and aggressive scrutiny. While this increased scrutiny is not limited to Swiss-based PCSs, Carl Bellingham and John Lindstrom of PwC warn that tax authorities may focus on a Swiss-based PCS due to the sheer number of such structures in Switzerland.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Thin capitalisation rules limit the amount of debt deductions that can be claimed but regard must also be given to other income tax law provisions, the ATO said
Pia Honkala, co-head of Aibidia’s operational TP product, tells ITR how her company works in harmony with advisers like the ‘big four’ to revolutionise clients’ processes
The UK is ‘heading to Scandinavia’ as its tax burden increases and isn’t creating an attractive environment for a wave of investment, experts have told ITR