The issue of the benefits or otherwise for developing countries of arbitration in tax matters has recently become more pressing. In this three-part series, 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.
The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs
The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed
Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars
DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations