The OECD’s work on base erosion and profit shifting (BEPS) is in the spotlight of worldwide taxation. Based on the Action Plan from last July and on two other reports – one published in March 2012 entitled Hybrid Mismatch Arrangements: Tax Policy and Compliance Issues and the other in February 2013 entitled Addressing Base Erosion and Profit Shifting – the OECD is clearly emphasising the need for action on this issue.
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Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
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