Fabrizio Lolliri, European director of transfer pricing at Hogan Lovells, and Catherine Clare, international tax manager at Tate & Lyle, a UK-based multinational agribusiness, explain how to make the most of your relationship with your transfer pricing adviser and how to review and set new transfer pricing policies, in the context of a large multinational enterprise.
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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