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TP for debt funds implemented in Luxembourg: mastering a dynamic environment

Dinko Dinev and Ismail Candan of Deloitte Luxembourg explain how tailored transfer pricing policies can underpin success as the increasing complexity of debt investment instruments and heightened regulatory oversight demand enhanced tax compliance measures ....

Pricing Guidelines For Multinational Enterprises , Anti Tax Avoidance Directive , Pricing Guidelines , Multinational Enterprises , Tax Administrations ,

Advice memorandum shows IRS approach to intercompany debt pricing

Mark Martin and Thomas Bettge of KPMG in the US discuss the issue of implicit support and a recent IRS advice memorandum addressing transfer pricing for intercompany debt ....

Tax Court , Revenue Service , Treasury Regulation , Pricing Guidelines , Tax Administrations , Internal Revenue Service ,

Guide to transfer pricing and financial transactions, with an Italian nuance

Carola Valente of Crowe Valente/Valente Associati GEB Partners explains the application of the OECD Transfer Pricing Guidelines to financial transactions as multinationals increasingly centralise their treasury functions ....

Supreme Court , Transfer Pricing Guidance , Financial Transactions , Inclusive Framework , Pricing Guidelines , Circular Letter ,