The CCCTB concept of relies on formulary apportionment, doing away with the arm’s-length principle (ALP). While many people welcome the opportunity to debate the future of tax compliance, others feel a switch to formulary apportionment will create just as many problems as the ALP. Sophie Ashley talks to the CCCTB’s critics and supporters about its impact on transfer pricing.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort