The OECD’s interim report on taxation of the digital economy examines the implications new nexus and profit allocation concepts could have on the international tax system. A re-evaluation of where value creation takes place will heavily impact big tech companies that use transfer pricing to shift profits to low-tax jurisdictions.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap