Since the arm's-length principle was introduced in Peru in 2001, there have been multiple updates and extensions to the rules on transfer pricing. Claudia González-Béndiksen and Paola Gutiérrez list the important points taxpayers must be aware of, such as maintaining stringent documentation as well as filing an annual sworn informative return.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
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