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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
ITR is delighted to reveal all the shortlisted firms, teams, and practitioners – winners to be announced on September 15
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Sponsored by Baker McKenzie LuxembourgThe technological revolution has led the OECD to attempt to redefine the concept of permanent establishments. Antonio A Weffer of Baker & McKenzie Luxembourg discusses how the related notion of the finance function is evolving in a digital cross-border setting. -
Sponsored by GNV ConsultingIndonesia has strengthened its tax disputes framework by adapting a more sophisticated procedure when handling advance pricing agreements (APAs) and mutual agreement procedures (MAPs). Charles Setia Oetomo and Felic Setiawan of GNV Consulting Services examine how the developments are an attractive premise for businesses in the region.
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Sponsored by Tax Partner AG, Taxand SwitzerlandHendrik Blankenstein, Tom Lawson and Caterina Colling Russo of Tax Partner AG – Taxand Switzerland present a comparative study on how the OECD’s guidance on financial transactions will impact the characterisation and pricing of inter-company loans for MNEs in Switzerland.
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