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Sponsored by Skeppsbron SkattMikael Jacobsen and Henri Ahtiainen of Skeppsbron Skatt explore how several recent Swedish cases have shed light on the complex distinction between legal and economic ownership of intellectual property in transfer pricing matters
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Sponsored by YulchonWith South Korea expected to intensify its focus on multinationals’ intercompany transactions during tax audits, Yulchon tax partners analyse several transfer pricing-related rulings that could help shape strategy
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Sponsored by Tax PartnerMonika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance
Transfer Pricing Guide archive
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Sponsored by Arendt & MedernachThe OECD has released its long-awaited transfer pricing guidance on financial transactions. Danny Beeton and Alain Goebel of Arendt & Medernach review the guidance and suggest the best approaches for pricing and documentation.
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Produced in collaboration with transfer pricing (TP) experts from across the globe, ITR is delighted to launch the 20th edition of our Transfer Pricing guide.
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Transfer pricing perfection may be out of reach but automation can bring you closer. Dianne Berry, Meenakshi Iyer, Jack O’Meara, Kirsty Rockall and Tim Wong of KPMG member firms in the UK, US and Netherlands look at how operational transfer pricing (OTP) is changing business for the better.
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Sponsored by GNV Consulting ServicesIndonesia 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 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.
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Sponsored by DS AvocatsCyril Maucour and Jessica Benchetrit of DS Avocats evaluate the effectiveness of the OECD’s new unified approach, which provides market jurisdictions greater taxing rights over residual profits.