OECD
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
The long-running dispute centres on Medtronic’s use of the comparable uncontrolled transaction TP method; in other news, Paul Hastings and FTI Consulting both made double tax hires
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Sponsored by Deloitte CanadaRalf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte reveal further insights from an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration
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Sponsored by DeloitteA three-part weekly series begins with Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte sharing insights from an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Marlinda Gianfrate of Gatti Pavesi Bianchi Ludovici focus on the evolution of multilateralism in tax treaties in the OECD context after a new agreement on a package to implement the two-pillar solution.
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