With the number of jurisdictions offering advance pricing agreements (APAs) increasing, delegates at International Tax Review’s 12th Annual Global Transfer Pricing Forum heard how, and why, this trend is set to continue, and to what extent the regimes already available are favoured by both taxpayers and authorities, including country-specific insights from the head of the French APA team.
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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