Despite criticism, financial institution notices look set to be introduced. Elena Rowlands and Ian Zeider (Travers Smith) explore what this could mean.
Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
The European Commission has a new ‘digital levy’ initiative, pending international consensus on digital taxation. Jennifer Maskell and Richard Sultman (Cleary Gottlieb Steen & Hamilton) consider how it might look.
We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) examine the proposals on ‘pillar one’ of an international solution to the taxation of multinational enterprises in the digital economy by 2020.