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Negotiations Continue on Pillar One

If you’ve been following negotiations surrounding the OECD’s global tax deal, then you know that the implementation of Pillar One has been pushed back to signing ceremony in mid-2023 with a possible roll-out in 2024.

New Documentation Requirements for the U.K.

For a country that so openly condemns tax evasion and avoidance, the U.K. would seem like an obvious candidate to adopt BEPS Action 13’s three-tier transfer pricing documentation requirements: the master file, the local file, and the country-by-country report.

Tax Dispute Costs McDonald’s €1.25 Billion

Royalty payments are almost always scrutinized by tax authorities, as they’re viewed as an easy way to shift profits outside of a rightful jurisdiction to a low-tax country.

US Ends Double Tax Treaty with Hungary

Looks like the global minimum tax is having a cross-border effect even before it’s actually implemented. Last week, the U.S. treasury announced that it would be ending a 43-year double tax treaty with Hungary.

What Can You Expect from Brazil’s New Transfer Pricing Rules?

If there’s one transfer pricing outlier in the world, it’s undoubtedly Brazil. The country’s transfer pricing model isn’t based on the arm’s length principle—instead, it adheres to fixed margins as opposed to comparability analyses.