The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. Michael Lennard, chief of the International Tax Cooperation section of the UN speaks in a personal capacity about some of the issues that may shape transfer pricing arbitration clauses and how they operate in future for taxpayers and their advisers.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation
Despite initial hopes that the reporting obligation had been suspended, compliance challenges brought by Brazil’s indirect tax reform are very much a reality