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.
Edward Morris and Jamie Hawes of Deloitte discuss how the resolution of controversy has changed with the introduction of a more efficient system to handle MAPs and APAs.
Juan Ignacio de Molina and Christine Ramsay of Deloitte consider the increased reliance of tax authorities on CbCR data and how the data reported in the CbCR during the COVID-19 pandemic could impede its use.
Shaun Austin, Richard Schmidtke and Aparna Rao of Deloitte discuss the challenging transfer pricing concepts of intangibles arrangements and important regulatory changes from Australia and Germany.
