The longer-term effects of the COVID-19 pandemic continue to make themselves known in the TP world, as companies consider how to make appropriate adjustments, and how to make comparability analysis work in this landscape. Suryani Suyanto & Associates, KPMG China, and Deloitte teams in the Philippines and Vietnam discuss.
Meanwhile, tax disputes continue with activity in some courts picking up after a lull during the height of the pandemic. Arendt & Medernach, Chevez, and GNV Consulting discuss the use of the mutual agreement procedure and advance pricing agreements to avoid, or tackle, disputes.
As Deloitte France explains, the OECD’s two-pillar global tax solution is under development following the agreement in October 2021, while LED Taxand writes about Italian case law on intercompany loans, and TaxPartner considers the deductibility of management fees in real estate funds.
Also in this guide, Deloitte Indonesia and Skeppsbron Skatt share the considerations that tax managers should bear in mind for intra-group TP transactions, DDTC examine the death of Libor in Indonesia, and Deloitte Thailand discusses recent TP developments in the country.
We hope you enjoy reading the 22nd edition of our Transfer Pricing guide.
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