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.
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.
Eric Lesprit and John Breen of Deloitte look to the future of transfer pricing dispute resolution, including the proposals in the OECD’s pillar one digital tax blueprint, multilateral negotiations and joint audits.
Alison Lobb and Howard Osawa of Deloitte explore potential areas of controversy arising from the G20/OECD’s pillar one and pillar two project and considerations to manage disputes and potential double taxation.
