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On 19 June 2023, the electorate and the cantons overwhelmingly approved (78.45% to 21.55%) the federal decree of 16 December 2022 on the special taxation of large multinational enterprises (MNEs), which would allow Switzerland to introduce the Global Anti-Base Erosion (GloBE) rules under the OECD...
Multinational entities (MNEs) are increasingly grappling with their global value chains (GVCs). Some MNEs are better than others, but current economic developments make it difficult to keep up and implement effective and efficient value chains.
One of the most difficult aspects of transfer pricing involves the use of comparable data and its application to attribute profits to related parties. In the best of times, finding comparables is onerous, but the challenges brought about by the Coronavirus Disease (“Covid-19”) and the resulting...
The Australian Tax Office (ATO) has released an updated draft Practical Compliance Guideline (PCG) on intangible arrangements (PCG 2023/D2) for public consultation and comments. The original draft (PCG 2021/D4) was released two years ago in May 2021, and there are significant changes in the...
As the financial year draws to a close, it's crucial for employers with an Employee Share Scheme (ESS) to turn their attention to their reporting obligations. Failing to comply with these obligations can result in administrative penalties, which can be easily avoided with timely and accurate...
India’s Foreign Trade Policy, 2023 (FTP 2023) became effective on 1 April 2023 replacing the policy for 2015-2020 that had been extended through 31 March 2023 as a result of the COVID-19 pandemic and ongoing geo-political situation (for prior coverage, see the article in the June 2021 issue of...
A bill published in Spain’s official gazette on 23 May 2023 transposes the EU DAC 7 directive into domestic law and simultaneously amends the General Tax Law to align it with the DAC 7 rules.
On 25 May 2023, the Spanish government published a law that removes the B2B supply of financial services (including insurance, reinsurance and capitalisation services) from the scope of the VAT use and enjoyment rule.
Attracting highly skilled professional athletes to sign contracts with Canada-based sports teams can be a challenge with Canadian income tax rates generally higher than those in its neighbour to the south.