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The EU's TP directive proposal: effective reform or a Hail Mary pass? - Vimarsana News

The EU's TP directive proposal: effective reform or a Hail Mary pass?

Ingrid Faxing and Henri Ahtiainen of Skeppsbron Skatt analyse a proposal to incorporate the OECD Transfer Pricing Guidelines into EU law and question whether it will become a reality after several objections

New Indonesian TP rule introduces double taxation prevention tool - Vimarsana News

New Indonesian TP rule introduces double taxation prevention tool

Tami Putri Pungkasan and Yurike Yuki of DDTC Consulting say an Indonesian transfer pricing update recognises the prevention of double taxation as a purpose and not merely as a means to prevent tax avoidance

Transfer pricing in Indonesia: an overdue revamp - Vimarsana News

Transfer pricing in Indonesia: an overdue revamp

Charles Setia Oetomo, Felic Setiawan, and Gomgom Johannsen Kevan of GNV Consulting provide a guide to Indonesia’s new transfer pricing regulation, what to expect, and how taxpayers may prepare for its application

United States: IRS can consider implicit support in intragroup loan pricing - Vimarsana News

United States: IRS can consider implicit support in intragroup loan pricing

The IRS Office of Chief Counsel recently issued a generic legal Advice Memorandum, AM 2023-008 ("GLAM"), confirming that the IRS may consider…

Deloitte OECD interview series – part three: Transfer pricing audits and dispute resolution - Vimarsana News

Deloitte OECD interview series – part three: Transfer pricing audits and dispute resolution

Ralf Heussner, Alison Lobb, and Yvonne Weigelt of Deloitte conclude their summary of an interview with Manuel de los Santos, head of the transfer pricing unit at the OECD’s Centre for Tax Policy and Administration