The FTA has amended its practice regarding profit repatriation in cases of primary adjustments that are partly or fully confirmed in a MAP. If a primary adjustment made by a Swiss cantonal tax administration is confirmed in whole or in part in the MAP, constitu...
Hence, a level of subjectivity on the selection of the most important comparability criteria, prioritisation in the search strategy, and the extent of comparability adjustments required in order to produce accurate results, is necessary. These practical considerations appear to be the key drivers of d...
Working-day adjustments As previously reported, our Germany business had two fewer working days versus the prior year, which impacted our fees and operating profit by c.£3.5 million. Therefore, on a WDA basis Group operating profit was £63.6 million, down 33% YoY, and represented a conve...