Following the introduction of the UK tax transparent fund (UK TTF) by the UK government in July 2013, we are now seeing real interest in the product and how it compares with vehicles already available in the European market. The first UK TTF was introduced by BlackRock Investment Management in June 2014, triggering debate about how these vehicles can be used to satisfy investor and business requirements.
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Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
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