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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 Deloitte Transfer Pricing GlobalEdward Morris and Jamie Hawes of Deloitte discuss how the resolution of controversy has changed with the introduction of a more efficient system to handle MAPs and APAs.
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Sponsored by Deloitte Transfer Pricing GlobalShaun Austin, Richard Schmidtke and Aparna Rao of Deloitte discuss the challenging transfer pricing concepts of intangibles arrangements and important regulatory changes from Australia and Germany.
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Sponsored by Deloitte Transfer Pricing GlobalEric Lesprit and John Breen of Deloitte look to the future of transfer pricing dispute resolution, including the proposals in the OECD’s pillar one digital tax blueprint, multilateral negotiations and joint audits.
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