The world of tax is rife with uncertainty like never before.
Led by tax reform in the US, large global businesses around the world are looking closely at both their supply chains and their organisational and legal structures, causing foreign governments to assess these businesses to prevent base erosion and profit shifting (BEPS).
Tax controversy is on the increase, and settling these disputes is rarely straight forward. Even before Country-by-Country Reporting (CbCR) disputes with tax authorities were on the rise, but in the last 18 months or so we have seen a crescendo of activity.
What does this look like?
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