Chinese transfer pricing rules and practices will break new ground in the coming years, finding solutions that cater to the special economic and commercial circumstances of China. Factors such as China market premiums and location savings will become more important in applying the arm’s-length principle, believe Cheng Chi, Irene Yan and Lu Chen of KPMG
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
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