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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 concludes the series by analysing the Dutch Tobacco BV ruling and approaches to transfer pricing guarantee fees in the Netherlands, India, and the UAE