The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year
Taxpayers should not overlook the hidden tools in the MAP toolbox when it comes to dispute resolution, particularly supplementary dispute resolution (SDR). Here Emile Simpson and Peter Nias write about the routes open to businesses.
Manisha Gupta, Iva Georgijew and Bhupendra Kothari of Deloitte discuss the transfer pricing risks that may arise due to business disruptions caused by COVID-19 with recommendations on how to manage those risks.
Ariel Krinshpun, James Mahon and Mo Malhotra of Deloitte explain why taxpayers may wish to review intra-group financing arrangements, and significant financing transactions in particular, for controversy risk.
Kerwin Chung and Howard Osawa of Deloitte preview ITR’s upcoming transfer pricing controversy guide, produced in collaboration with global transfer pricing experts from Deloitte.