Source Country (BRICS) Model Treaty Posture and Planning for the Future


Of all the international tax issues on the agenda today, perhaps the most difficult for both tax administrations and multinational entities (MNEs) is the tension between Organisation for Economic Co-operation and Development (OECD) member countries and the rest of the world with respect to transfer pricing (TP) principles. MNEs find themselves in the middle, producing a material danger of double or multiple taxation.

There are at least six groups with distinct voices in this area of tension...

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