In recent years the need for certainty on the tax affairs of a multinational has become a strong preference for both taxpayers and tax authorities alike. Cross-border cash and asset flows are seen to present a high risk and the scope for non or double taxation continues to increase as globalisation of business accelerates. Furthermore tax has gained high prominence in corporates and has finally made it onto the boardroom agenda. Whether that is through the efforts of tax administrations such as HMRC in-house tax staff or just the bottom-line impact of things going wrong is a moot point.
The increasing need for certainty on tax matters also runs parallel to a changing fiscal environment. The popular view that large corporates should act morally by paying the 'right' amount of tax has been a keen topic in the UK media in past years. Tax authorities have also been...
