Another year of transfer pricing development brings hope, for taxpayers and their advisers, that processes will be streamlined, guidelines will provide clarity and policy reform will allow for better interpretation. A new year allows for contemplation about the direction governments and tax authorities should take. Sophie Ashley reports on the expectations of global and regional advances.
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Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
The Brazilian law firm partner warns against going independent too early, considers the weight of political pressure, and tells ITR what makes tax cool
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires