The effective implementation of the arm’s-length principle is closely linked to the availability of information. In transfer pricing, the asymmetry of information between taxpayers and tax administrations can be acute, potentially opening opportunities for BEPS. For this reason, the BEPS Action Plan stressed the need to enhance transparency in general, and for transfer pricing purposes in particular. Andrew Hickman, Samia Abdelghani and Paul Hondius explain these enhancements in the context of Action 13.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda
Historical claims involving KPMG Australia's tax practice have surfaced as the firm battles a separate parliamentary inquiry into its handling of whistleblowers
While AI is revolutionising tax work, it is also reshaping clients’ willingness to pay for advice and their perception of the value generated by tax advisers
The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward