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 ARKKWith transfer pricing complexities set to increase in 2023, Rahila Zahin of ARKK explains how automating processes can help. -
Sponsored by KPMG ChinaLewis Lu and John Timpany of KPMG China discuss Hong Kong SAR government’s open letter which indicated the deferral in implementation of global minimum tax under BEPS 2.0 in Hong Kong SAR.
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Sponsored by DeloitteIncreased transfer pricing documentation requirements are not reducing the number of disputes. Jennifer Breeze, Chris Ferguson, and Simón Somohano of Deloitte offer regional perspectives on the issue and explain what businesses may be able to do to prevent escalation.
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