DOCUMENTATION
Documentation
Learn how to use Meridian
Getting Started
Platform overview and first steps
Platform Features
Treaty & Cross-Border
Permanent Establishment
PE risk assessment under treaty and domestic law
Withholding Tax
Cross-border payment classification and treaty relief
Transfer Pricing
Arm's length analysis, DEMPE, and TP documentation
Tax Residence
Domestic tests, treaty tie-breakers, and dual residence
Capital Gains
Art. 13 analysis for share and asset disposals
MLI & Treaty Shopping
PPT, LOB, and anti-avoidance treaty provisions
Anti-Avoidance & Compliance
CFC Rules
Controlled foreign company analysis with ATAD compliance
Interest Limitation
EBITDA-based restrictions under BEPS Action 4 and ATAD
ATAD Anti-Avoidance
GAAR, exit tax, hybrid mismatches, and switch-over
Substance Requirements
Economic substance for holding and IP structures
Pillar 2 / GloBE
Top-up tax, safe harbours, and ETR computation
Pillar 1
Amount A/B, nexus, revenue sourcing, and profit allocation
Advanced & Procedural
Exchange of Information
CRS, DAC6/DAC7, FATCA, and spontaneous exchange
MAP & Arbitration
Mutual agreement procedures and mandatory binding arbitration
Digital Services Taxes
Country-specific DSTs and Pillar 1 phase-out
Cross-Border M&A
Share vs asset deals, Merger Directive, and restructuring
Country-by-Country Reporting
BEPS Action 13 filing, thresholds, and safe harbours
Beneficial Ownership
Treaty context, conduit analysis, and key case law