In his February 17 economic note, Australian Treasurer Wayne Swan talked of the increasing trend of multinational profit shifting, throwing his weight behind earlier comments from his counterparts in France, Germany and the UK. Now, Assistant Treasurer David Bradbury has reinforced the Australian government’s stance by claiming that protection of the tax base is the “most significant challenge to the world’s major advanced economies”.
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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
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires