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.
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Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’
The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions
IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing
As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency