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  • In the last few decades, stock option plans have consolidated in the US and Europe as a relevant instrument of long-term incentive for executive and employees.
  • Phil Fortier, Alex Evans, and Raf Sattar of Deloitte in Canada summarise the key aspects of Canada’s APA programme report for 2017, allowing taxpayers and tax practitioners to align expectations of the scheme with the current approach.
  • The US Tax Court will have to once again review whether Medtronic’s use of the comparable uncontrolled transactions (CUT) method complied with regulations after the Eighth Circuit Court referred the case back for deeper analysis.
  • Georgios I. Katrinakis
  • Teodosia Kirilova
  • Chris Damianou
  • Eija Kuivisto
  • Petr Toman
  • Bernhard Groehs
  • At the regional level, there is a strong concern regarding the European Commission activity, following the Base Erosion and Profit Shifting works and recommendations. So EU governments and tax administrations are looking carefully at the same options, even if, of course, the intensity varies from one Member State to another. Looking at some countries, and more specifically at France, there is an increased, ongoing pressure from tax authorities regarding things like tax raids.