The shale industry is booming across the world with companies keen to exploit the rapid development in this sector. Randy Price, Nadim Rahman and John Wells of Deloitte explain that as the industry grows, transfer pricing will take centre stage, and offer insight on how effective tax planning and addressing the transfer pricing rules are crucial to managing risk.
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While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems