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Recharacterisation in transfer pricing audits: focus on Poland and Germany

by usoftax_admin | Sep 25, 2024 | Tax News

Mariusz Każuch, Inka Traeger, and Conrad Marburg of Deloitte consider tax authorities’ recharacterisation of intercompany transactions through drawing on recent practice in Poland and Germany, and suggest proactive measures global businesses can take

Cooperative and preventive programmes: the panacea to TP controversy?

by usoftax_admin | Sep 25, 2024 | Tax News

Carlos Serrano Palacio, Richie Lombard, and Bernardo Misle of Deloitte analyse recent measures to resolve tax uncertainty in a climate of increasing transfer pricing audits and controversy, and consider what further steps should be taken

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

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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