NEXUS-APPROACH

Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.

Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) examine the proposals on ‘pillar one’ of an international solution to the taxation of multinational enterprises in the digital economy by 2020.

The OECD's programme of work subtly recasts the two pillars proposed in its earlier consultation, as Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) explain.

How does the ‘nexus’ approach, proposed by the UK and Germany for future IP regimes, differ from the ‘transfer pricing’ approach of the UK patent box, asks Peter Denison-Pender (MMP Tax Ltd)