The financial services industry seems certain to navigate 2012 through turbulent waters with the eurozone crisis unfolding by the day, the increasingly visible hand of state regulation and bailouts, political sensitivity cumulating in the Occupy Wall Street protests, and the surging influence of the G20 emerging economies in global finance. Sam Sim and Akiko Sumikawa, two financial services transfer pricing specialists, for a leading global bank, say that taxpayers who assume the present trend will continue risk missing some forces already upon us that are shaping the future of financial services transfer pricing (FSTP).
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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