Czech Republic
The case shows that legal relationships between parties bear significance and should be given sufficient weight in TP analyses, one local adviser says
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR
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Sponsored by Deloitte Transfer Pricing GlobalEddie Morris, Jennifer Breeze and Janelle Sadri discuss how the growth in the number of mutual agreement procedures, coupled with fine-tuning of the process, has affected its themes of access, resolution and implementation. -
Sponsored by Deloitte Transfer Pricing GlobalEric Lesprit, Mariusz Każuch and Howard Osawa look at three national case studies and consider whether the increased use of international data improves cooperation among tax administrations.
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Sponsored by Deloitte Transfer Pricing GlobalMo Malhotra, Ariel Krinshpun and Ockie Olivier evaluate how the OECD guidance on financial transactions will influence an increasingly convoluted transfer pricing environment.
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