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.
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.
Kerwin Chung and Carlo Llanes Navarro of Deloitte provide an insight into ITR’s transfer pricing controversy guide, produced in collaboration with global transfer pricing experts from Deloitte.
Vrajesh Dutia and Ananthanarayanan R of Deloitte analyse the results of a TP controversy survey, involving TP practitioners across the globe, which seeks to gain a better understanding of the ever-evolving TP landscape.
