Martin Zetter comments on the OECD's white paper on transfer pricing documentation and thelatest proposals to amend its transfer pricing guidelines on intangibles.
John Manis suggests a simpler solution to deal with ‘disguised employment’ than the one set out in the partnership tax consultation
Gary Richards criticises HMRC’s conduct in the GSTS Pathology case.
Graham Elliott writes that the Ocean Finance judgment might not be as beneficial to HMRC as the department suggests
John Hayward questions whether the pensions tax regime introduced in 2006 achieved the simplification it intended
Some immediate reaction on the OECD's Action Plan on Base Erosion and Profit Shifting.
It is important that changes to rules where a lender swaps debt for equity do not give rise to uncertainty that could prevent commercial rescues, writes Michael Bacon
A basic transfer pricing model may be the fairest approach, says Sara Luder
A tonnage tax case has implications for the loan relationships rules, writes Heather Self