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Transfer Pricing (18th edition)

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    Transfer Pricing is available as a downloadable pdf.

  • BEPS: The endgame

  • IP migration strategies – pre-and post-BEPS

    BEPS aims to prevent aggressive profit-shifting strategies to better align transfer pricing outcomes with value creation. In this paper, Dale Hill, a partner at Gowling WLG, examines BEPS’s application to the transfer pricing aspects of intangibles and the impact on tax-motivated IP migration strategies.

  • There is more to BEPS than meets the eye

    Much lies beneath the surface of BEPS. How will BEPS affect Korean multinationals and what do MNEs need to learn? Tae Hyung Kim, partner and senior transfer pricing economist at Deloitte Korea, explains exactly what multinationals must consider and what they should fear.

  • Intangibles in a post-BEPS world

    The framework for analysing intercompany transactions involving intangibles is examined by Hendrik Blankenstein and Caterina Colling Russo at Tax Partner AG – Taxand Switzerland. Does the new DEMPE analysis benefit MNEs and tax authorities or simply confuse matters, resulting in an increase of intangibles-related disputes?

  • Responding to the changes in the transfer pricing landscape

    The Internal Revenue Service appears to be strengthening its stand on aggregating transactions and applying economic substance rationales to override related-party contracts. David Forst and Larissa Neumann of Fenwick & West discuss US developments including the IRS and Treasury Department-issued 482 Temporary Regulations.

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