Russia's new transfer pricing rules usher in a qualitatively new outlook in how the Russian tax authorities will consider intercompany transactions for tax purposes. Although some aspects resemble OECD principles, there are also significant deviations. Svetlana Stroykova, Ilarion Lemetyuynen, Adam Kosmala and Andrew Joshi of PwC provide an overview of the recent changes.
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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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