In light of the US Tax Court’s decision in Amazon v. Commissioner of Internal Revenue, many important predictions have been made about the impact this case will have on future transfer pricing litigation. However, it is important to look at the valuable lessons that should be learned by practitioners, corporations, attorneys, and tax authorities when documenting intercompany transactions, specifically intangibles. John Wiora, director of operations at ktMINE, investigates.
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While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort