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Transfer pricing controversy trends – Deloitte’s 2024 global survey

by usoftax_admin | Sep 25, 2024 | Tax News

Shaun Austin, Darcy Alamuddin, and Ryan McMahon of Deloitte analyse the feedback from the 2024 Deloitte transfer pricing controversy survey, highlighting key trends in the transfer pricing controversy space

High-value service charges and transfer pricing controversy

by usoftax_admin | Sep 25, 2024 | Tax News

Nicola Lostumbo and Jie Pan of Deloitte provide insights into high-value intercompany service charges, their role in creating value, and the most common tax authority challenges, before concluding with some considerations in mitigating risks

Intangibles transfer pricing, transaction delineation, and corporate dynamism

by usoftax_admin | Sep 25, 2024 | Tax News

With the pricing of intangibles laced with difficulty, Ishan Maini, Eric Linge, and Richard Schmidtke of Deloitte draw on two cases in Germany and Israel revolving around differing interpretations concerning the delineation of transactions

Brand value: drawing the link between value creation and economic benefit

by usoftax_admin | Sep 25, 2024 | Tax News

The complex distinction between legal ownership and economic ownership of intangible assets means multinationals must take proactive measures to avoid transfer pricing controversy, say Christine Ramsay, Jordi Morera, and Marguerite Mei of Deloitte

Puerto Rico Seeking Input On Implementing Global Min. Tax

by usoftax_admin | Sep 25, 2024 | Tax News

Puerto Rico’s Department of the Treasury is looking for public comments regarding possible implementation of the Organization for Economic Cooperation and Development’s 15% global corporate minimum tax on large multinational entities.

Swedish Tax Agency prevails in case involving TP and intangibles

by usoftax_admin | Sep 25, 2024 | Tax News

Åsa Edesten and Mazlum Yildiz of KPMG Sweden say there remains a lack of clear legal precedent on the impact of ‘control over risk’ in assessing contractual terms between related parties, despite a recent ruling
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