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.
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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year