Brad Rolph of Charles River Associates in Canada takes a closer look at the memorandum of understanding (MOU) on arbitration between the US and Canada and the accompanying arbitration board operating guidelines. He also examines whether the arbitration procedure is accomplishing its objectives to reduce the amount of time it takes to resolve double taxation cases and increase the use of principle-based negotiating positions.
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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
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