After years of international criticism over the lack of a transfer pricing regime, the Netherlands is finally codifying its arm’s-length principle. Proposed documentation requirements increase the administrative
burden, so companies should review their arrangements well in advance. Eduard Sporken, KPMG Global Transfer Pricing Services, Amstelveen
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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