Harmonising a company’s transfer pricing documentation with customs requirements has always been a contentious issue because of the inconsistencies between the two regimes. David Grace, Emin Toro and Mateo Caballero from Covington & Burling explain how taxpayers can make this process easier.
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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