Taxpayers and authorities are alive to the calls for greater transparency. And though this is building public pressure on tax authorities to milk multinational cash cows for all they can get, there is a growing realisation among authorities that ill-designed international tax rules and strains on resources, as well as the complex manner in which multinationals arrange their tax affairs, means that working with – rather than against – the largest taxpayers is the best way forward.
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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