The IRS’ Action on Decision (AOD), on November 10 2010, stating it does not agree with the result or reasoning of the US Tax Court’s decision in Veritas Software Corp. v. Commissioner, brought a spectrum of transfer pricing conflicts to light as the US Tax Court and IRS struggle to find common ground.
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The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals