The international tax compliance landscape has become increasingly complicated and is often unclear. The main reason for this has been due to a proliferation in domestic measures (sometimes with extraterritorial application), such as FATCA, the Russian GAAR and the UK Criminal Finances Act 2017, which consequently require enterprises with a multinational presence to comply with such varying measures across the countries in which they operate. This is compounded by measures introduced through international instruments, such as in relation to hybrid entities in the OECD’s multilateral instrument (MLI) and DAC6.
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The international tax compliance landscape has become increasingly complicated and is often unclear. The main reason for this has been due to a proliferation in domestic measures (sometimes with extraterritorial application), such as FATCA, the Russian GAAR and the UK Criminal Finances Act 2017, which consequently require enterprises with a multinational presence to comply with such varying measures across the countries in which they operate. This is compounded by measures introduced through international instruments, such as in relation to hybrid entities in the OECD’s multilateral instrument (MLI) and DAC6.
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