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Transfer Pricing
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
February 26, 2026
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  • Hans Grimbergen and Ivo Middelink of Ernst & Young Belastingadviseurs argue that the Dutch secretary of state has not gone far enough in overhauling the tax treatment of interest on acquisition debt and look at the various tax aspects of M&A which are causing problems in the Netherlands.
  • Abhishek Shah of Ernst & Young analyses the indirect tax proposals of the Indian budget and finds there is not much good news for taxpayers.
  • On February 13 2013, the OECD released a report on tax planning by multinationals that reduces group corporate tax liability to an unacceptably low level, as a first step against base erosion and profit-shifting (BEPS). In the preceding months Starbucks, Google and several others were publicly attacked for not paying their “fair” share. Johann Muller, a member of the international corporate taxation department at the Danish Tax Authority – submitting this article in a personal capacity in advance of the OECD Working Party No 6 meeting in March – examines the issues that need to be addressed when looking at examples 1 and 2 to Annex C of the BEPS report.

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