The concept of a principal company structure (PCS) is far from new, yet national tax regimes are increasingly targeting these structures for enhanced and aggressive scrutiny. While this increased scrutiny is not limited to Swiss-based PCSs, Carl Bellingham and John Lindstrom of PwC warn that tax authorities may focus on a Swiss-based PCS due to the sheer number of such structures in Switzerland.
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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
Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four
HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test