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Kapil Sethi and Mithilesh Reddy of Steadfast Business Consulting examine why financial transactions remain a transfer pricing battleground six years after the OECD’s Chapter X guidance, and what taxpayers should do about it
In the first article of a three-part series, Mithilesh Reddy of Steadfast Business Consulting decodes a memorandum issued by the Dutch tax authorities that addresses implicit support and recharacterisation, and explains the implications for multinationals
Mithilesh Reddy of Steadfast Business Consulting continues his analysis of the May 2025 memorandum issued by the Dutch Coordination Group on Transfer Pricing, focusing on the conditions that guarantee fees must meet
