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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Pillar Two: Side-by-Side issues, and the Belgian UTPR case
European scrutiny of the Side-by-Side Package continues, with critical reviews in the Netherlands and potential delays to DAC6 reportingrelief. As the legal challenge to Belgium’s UTPR proceeds, Pillar Two may survive, but look increasingly less like a single coordinated global minimum tax, and more like a collection of national rules.
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