Anti-tax avoidance, Arbitration, BEPS, COVID-19, International Tax Law, MNE Profits, OECD, Permanent Establishments, Tax risks, Transfer Pricing
Transfer pricing and the Corona pandemic
In my last blog, I looked at the immediate impact of Covid 19 Lockdowns on key elements of double tax treaties – residence, permanent establishment and employment income. Many tax administrations have published guidance on their approach to these issues. Indeed, almost immediately after the OECD also published helpful comment on them too. The general…