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.
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
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