In order to fulfil the government’s aim to introduce a series of measures to mitigate tax evasion, the Argentine executive has finally promulgated, on October 21 2003, a tax reform Bill where for exports of grain, hydrocarbons and other commodities involving a foreign intermediary, the fair-market price of the goods at the date of loading may be used rather than the price fixed in the transaction if the intermediary does not fulfil certain conditions
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems