Companies are advised to check for relevant changes to their respective domestic laws following the signing of the OECD’s multilateral instrument (MLI) by 76 countries with much fanfare on Wednesday. The rewriting of bilateral taxation treaties on such a large scale is expected to improve arbitration in tax dispute resolution and curb double taxation, but is likely to be implemented to varying degrees across jurisdictions.
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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
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