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.
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