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.
This week Barclays’ tax affairs came under scrutiny after claims the bank avoided paying UK corporate tax via a Luxembourg structure, while the European Commission put forward its long-awaited proposal for an equity tax incentive.
Tax consultants and in-house tax directors say companies and tax authorities could benefit from the use of blockchain technology to file more accurate TP documentation.
MNEs need digital solutions that can handle cross-border compliance and the demands of the supply chain. Christiaan Van Der Valk, vice president for strategy and regulatory at Sovos, discusses how to approach this.
Frank Schoeneborn and Divya Vir Rastogi of EXA AG discuss how the development of state-of-the-art operational transfer pricing solutions are enhancing the day-to-day work of tax professionals.
The technological revolution has led the OECD to attempt to redefine the concept of permanent establishments. Antonio A Weffer of Baker & McKenzie Luxembourg discusses how the related notion of the finance function is evolving in a digital cross-border setting.
The OECD has released its long-awaited transfer pricing guidance on financial transactions. Danny Beeton and Alain Goebel of Arendt & Medernach review the guidance and suggest the best approaches for pricing and documentation.