Gideon Sanitt and Batanayi Katongera (Macfarlanes) review the state of play and the current steps being taken by the UK to implement the measures.
The Leaders’ Declaration issued following the June 2015 G7 summit stated: ‘we will strive to improve existing international information networks and cross-border cooperation on tax matters including through a commitment to establish binding mandatory arbitration’ (emphasis added).
Action 14 of BEPS expresses the widely-held view that the best way to ensure that cross-border transfer pricing disputes are effectively resolved is through mandatory binding arbitration. Without it an increase in such disputes is inevitable.
The MAP
On 1 February 2018 HMRC published revised guidance and a new Statement of Practice SP 1/2018 summarising the UK’s practice in relation to methods for reducing or preventing double taxation. The new guidance is consistent with the OECD recommendations on Action 14.
In the new...
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Gideon Sanitt and Batanayi Katongera (Macfarlanes) review the state of play and the current steps being taken by the UK to implement the measures.
The Leaders’ Declaration issued following the June 2015 G7 summit stated: ‘we will strive to improve existing international information networks and cross-border cooperation on tax matters including through a commitment to establish binding mandatory arbitration’ (emphasis added).
Action 14 of BEPS expresses the widely-held view that the best way to ensure that cross-border transfer pricing disputes are effectively resolved is through mandatory binding arbitration. Without it an increase in such disputes is inevitable.
The MAP
On 1 February 2018 HMRC published revised guidance and a new Statement of Practice SP 1/2018 summarising the UK’s practice in relation to methods for reducing or preventing double taxation. The new guidance is consistent with the OECD recommendations on Action 14.
In the new...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
