The US Customs and Border Protection (US CBP) published a Notice on May 16 revoking a Headquarters Ruling, HRL 54764 (November 8, 2001). The revocation should make it easier for companies importing products purchased from a related party to navigate the potentially conflicting rules and procedures for complying with US transfer pricing rules, while properly reporting the dutiable value of property imported from a related party.
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Belt and Road Initiative countries face tax incentive conundrums due to pillar two, but relatively few countries would seek to scrap the project, ITR has heard
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While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness