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Transfer Pricing
MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
July 10, 2025
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  • The UK’s corporate criminal offence (CCO) legislation to combat tax evasion represents another pressing reason, and opportunity, for tax functions in multinationals to work closely with colleagues across the organisation, writes Sandy Markwick.
  • The June 21 decision by the US Supreme Court in South Dakota v Wayfair Inc that overturned, by a 5-4 majority, the previous leading case of Quill Corp v North Dakota has a significant effect on sales taxes within the US. But should businesses outside the US also be very concerned, given that some initial commentary suggested that this would result in a rapid change of the definition of permanent establishment?
  • Jasper Korving and Loes van Hulten of Deloitte provide an overview of the MLI, focusing in particular on the principal purpose test (PPT), an anti-treaty abuse measure in the convention, how the PPT might apply in practice, and its potential impact on companies.

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