Why the UN tax process remains worth watching
The UN tax process is worth watching as potentially significant new ideas on taxable presence and profit allocation are being explored. TheNetherlands, for its part, is considering a middle ground on taxing cross-border services, suggesting that attitudes toward source-country taxation may be shifting even among developed countries.
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Diverging OECD and UN approaches to transfer pricing
UN proposals on taxable presence and profit allocation, OECD revisions to intra-group services guidance, and evolving dispute resolutionmechanisms point to increasingly different approaches to transfer pricing. For multinationals, these differences could mean greater uncertainty over where profits are taxed and increased exposure to double taxation.
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