The OECD has published a 42-page Country-by-Country Reporting Implementation Package this week, which consists of model legislation, a multilateral competent authority agreement on the exchange of country-by-country reports, two other competent authority agreements, one based on a double tax convention, the other based on a tax information exchange agreement (TIEA), and a confidentiality and data safeguards questionnaire.
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A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation
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