Council Directive (EU) 2018/822 (generally known as DAC 6) expressly provides for reporting obligations concerning cross-border arrangements that present an indication of a potential risk of tax avoidance. The Annex to the Directive lists the hallmarks triggering reporting obligations, which include the category of specific hallmarks concerning transfer pricing (Category E). The first of these…
I. Introduction Shall international tax planning decrease after the implementation of BEPS? The reply is “depends” by virtue of the subject’s exposure to several variables. Obviously, one should consider the question in the light of the legislative framework and tax environment of the relevant country which is in principle the country for which tax planning…
The OECD Public Discussion Draft on BEPS Action 14 (released on 18 December 2014) covers extensively dispute resolution mechanisms and ways to make them more effective. The subject has grown in importance as Mutual Agreement Procedures (“MAP”) have increased significantly especially on transfer pricing cross border adjustments. In this context, the BEPS Discussion Draft states…
