The tax authorities in the US have designed regulations to encourage employees to come forward with information about a corporation’s aggressive tax planning schemes, with promises of hefty rewards for tips that leads to the recovery of money. Erin Kelechava finds that these regulations and other new IRS initiatives, such as Schedule UTP, may complicate matters for corporate tax departments by requiring that they increase transparency, institute internal controls, and scrutinise their tax positions.
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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
ITR understands that UK Chancellor Rachel Reeves will announce a consultation on the proposed financial reward scheme, which had left advisers fretting
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires