Base erosion and profit shifting (BEPS) regulations are becoming more onerous as part of an OECD initiative. What advice do you provide around this to your clients with operations in multiple jurisdictions?
Luxembourg recently introduced into domestic tax law the basic transfer pricing principles foreseen by Articles 8 -10 of the OECD BEPS report. Luxembourg will have to implement the anti-tax avoidance directive which includes the principles set out by the OECD BEPS report as regards hybrid mismatch (Action 2), CFC Rules (Action 3), Limitation of Interest […]