Sarah Norton summarises the changes regarding real-time working of transfer pricing issues and Advanced Pricing Agreements, cost contribution agreements and share options
Robert Langston outlines how commissionaire structures operate and the resulting tax risks following the Dell and Zimmer cases.
James Bullock explains the best course of action for resolving a tax dispute
The objective of holding multinationals to account in relation to tax planning strategies – one of six stated ‘possible objectives’ – was discounted by a group of tax experts and practitioners reporting to the OECD in April on the case for greater disclosure of tax information.
Bank loans to corporate borrowers are often supported by guarantees from related companies. Lydia Challen and Tim Harrop identify the principal tax issues on the provision of such a guarantee, from its creation to its termination