
Transfer Pricing Guide 2025
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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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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 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 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 Deloitte LuxembourgRalf Heussner and Iva Gyurova of Deloitte Luxembourg explore the key global transfer pricing trends of the coming years, which will influence businesses and taxpayers in the financial services sector.
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Sponsored by SF Consulting/Crowe IndonesiaSri Wahyuni Sujono and Gandi Siregar of SF Consulting/Crowe Indonesia summarise the tax audit procedure in Indonesia, while explaining why pressure to achieve tax revenue targets in 2020 may stimulate an aggressive approach.
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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.