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OECD publishes proposal to tax profits in countries where customers are located

On 9 October 2019, the OECD published a proposal with the aim to ensure that large and highly profitable multinational companies, including digital companies, pay taxes where they have important consumer-oriented activities and generate profits. A...
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Tax function and software as a solution for transfer pricing and more

When I started my career as tax manager of a listed MNE, transfer pricing topics were only for the happy few. In those years I was already often consulted on this topic by colleagues of other MNEs and was asked “how to handle transfer pricing”. Th...
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Mandatory Disclosure rules: time to act now!

MNEs will have to develop a policy In 2018, the EU adopted new minimum rules for the disclosure of potentially aggressive cross-border tax planning arrangements. EU Member States have to implement these rules in their domestic legislation on 31 De...
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£107 million Diverted Profit Tax charge to Diageo: Is it a tax?! Is it a penalty?! Or is it proof that HMRC has superpowers…

On May 10, Diageo, a FTSE 100 alcoholic beverage company, reported that it will have to pay a Diverted Profit Tax charge of £107 million in relation to a period of just 15 months. This evidences the approach HMRC is taking in inquiries where it do...
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