MAPping the way forward in international tax disputes
Statistics released by the OECD for 2019 (see here) show that the trend for increasing use of the mutual agreement procedure (“MAP”) as a...
Statistics released by the OECD for 2019 (see here) show that the trend for increasing use of the mutual agreement procedure (“MAP”) as a...
The impact of COVID-19 will likely be felt most keenly by those with pending litigation but it will also affect those with ongoing HMRC...
On 27 January 2020, HMRC published its latest statistics on diverted profits tax (DPT) and transfer pricing, covering the period up to...
Yesterday, HMRC announced the introduction of a “Profit Diversion Compliance Facility”. In very basic terms, the Facility is targeted at...
HMRC is apparently not satisfied with the range of tools now at its disposal to impose UK tax on the value generated from the UK using...
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