Philip Baker KC (Field Court Tax Chambers) considers why existing rules struggle to tax cross-border services effectively and proposes an alternative solution.
Alison Lobb and Lisa Shipley (Deloitte) examine how national variations in Pillar Two, including local accounting standards and safe harbour restrictions, increase complexity and compliance costs for multinational groups.
Chris Sanger and Ian Dennis (EY) set out four possible futures for Pillar Two, exploring the competitive implications of the Side-by-Side regime and the practical choices facing heads of tax.
Giorgia Maffini (PwC) considers whether OECD transfer pricing reforms will deliver simplification or greater scrutiny, focusing on intra-group services, Amount B and growing differences between jurisdictions.
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) agreed a Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy. Pillar One of the Two-Pillar Solution contains two...
Liesl Fichardt and Julius Berling (Quinn Emanuel) examine OECD, EU and UN initiatives to improve international tax dispute resolution, as well as the increasing use of domestic alternative dispute resolution.
Moshe Spinowitz and Jisun Choi (Skadden) assess the growing attractions of a US parent company following tax reforms and the Side-by-Side package, explaining the trade-offs and complexities involved in relocating.
Writing on behalf of The 100 Group’s Tax Committee, David Gordon calls for stable business taxes, simpler rules and wider access to advance tax certainty to help the UK compete for investment.
