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International tax and treasury issues in 2021

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The evolving treasury and international tax landscape makes it important to revisit the tax treatment of finance and treasury transactions. In particular, a group should review its CIR position in light of the impact of the covid-19 pandemic. Increased foreign exchange volatility means a group should ensure it is appropriately hedged from a tax perspective. Treasury teams may need supporting when refinancing debt, including for both external and internal hedging strategies if looking to take advantage of historically low euro interest rates. A group’s VAT strategy should be reviewed in light of Brexit. Transfer pricing positions should be reviewed and potentially redocumented following new OECD guidance.
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