The Resource Planning for multilateral tax controversy in the post-BEPS world

Planning for multilateral tax controversy in the post-BEPS world

Label
Planning for multilateral tax controversy in the post-BEPS world
Title
Planning for multilateral tax controversy in the post-BEPS world
Creator
Subject
Language
eng
Summary
All multinational groups (MNEs) are, should or will be addressing their existing international tax planning structures with respect to a new world that is rapidly changing in apparently dramatic ways. The process may be supervised at the level of the board of directors, reflecting the seriousness of elements on the horizon. The changes on the horizon are prefaced with the word 'apparently'. The authors use this term because the changes are only new in the sense of potentially being required on a global basis. Over the past 30 or so years, a similar process has occurred in certain countries on an examination and dispute resolution basis. MNEs have provided complete information in such contexts, and the disputes between treaty countries have been resolved via treaty-based mutual agreement procedure (competent authority) proceedings which are indeed non-transparent (i.e. in the dark for the rest of the world) or before the courts in instances where there is no applicable treaty (judicial decisions are open for review, but tend to be far different than treaty-based solutions). Knowledge gained from these prior periods may be instructive in terms of the way forward with the developments in place or on their way. This article reviews the realities on the horizon and suggests means by which MNEs can prepare for the arrival thereof by reference to experience over the years
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 22 (2015),
http://library.link/vocab/creatorName
  • Lowell, C.H
  • Herrington, M
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • BEPS
  • CbCR
  • exchange of information
  • State aid
  • exit tax
Label
Planning for multilateral tax controversy in the post-BEPS world
Instantiates
Publication
Label
Planning for multilateral tax controversy in the post-BEPS world
Publication

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