Intellectual property (IP) is the major value driver in the global value chains of multinationals. Correspondingly, given its impact on profit allocations between group affiliates, it is also the most controversial transfer pricing issue both in tax legislation and tax audit practice. Yves Herve and Susann van der Ham of PwC focus on German particularities that arose out of new tax legislation from four years ago.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
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
The deal establishes Ryan’s property tax presence in Scotland and expands its ability to serve clients with complex commercial property portfolios across the UK, the firm said