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Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Christos Theophilou and Demis Ioannou of Taxatelier present a case study of how the Cypriot tax authorities use safe harbour rules in determining arm’s-length interest rates.
Christos Theophilou and Costas Savva of Taxatelier consider how the OECD’s guidance on financial transactions and transfer pricing (FTTP) can be interpreted in consideration of intra-group loans.
Hendrik Blankenstein, Tom Lawson and Caterina Colling Russo of Tax Partner AG – Taxand Switzerland present a comparative study on how the OECD’s guidance on financial transactions will impact the characterisation and pricing of inter-company loans for MNEs in Switzerland.