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International holding structures: are they structurally sound?

Jenni Bullivant, Creina Kane and Aaron Mehta (PwC) reflect on the host of international tax issues and complexities associated with international holding structures as a consequence of the continually changing external landscape. 

It has been impossible to miss the global shift in recent years calling for greater tax transparency reform of taxing rights and demands for taxpayers to pay their ‘fair share’. The response which started domestically has spread to the construction of wider reaching international tax reform. This development has been heightened in light of a global pandemic which has seen governments pour funds into maintaining the structural integrity of economies across the world. Once the dust has settled large multinationals will likely be asked to play their part in reducing deficits through further reforms of the global tax system.

Reform started when the OECD initiated its...

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