When Goldman Sachs economist Jim O’Neill coined the BRIC acronym in 2001, his new term was born out of a desire to group together those countries viewed as emerging growth markets. The grouping worked because it was clear these countries shared common features, which marked them apart from the rest of the world. That being the case, it is no surprise that the tax structures employed in these countries often need to be different from those used elsewhere. Matthew Gilleard talks to taxpayers and advisers about such structures, what the common mistakes are, and what taxpayers can and cannot do, as compared to tax rules elsewhere.
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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