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Philippines as a global tax leader | Joel L. Tan-Torres

Part nine The more important contributions of the Organization for Economic Cooperation and Development (OECD) in the field of taxation are its research and publication of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“transfer pricing guidelines”). This resource has long been referred to by various nations and… ....

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The use of profit splits in commodity trading and banks – a natural alignment?

Geoff Gill of Deloitte Australia and Andrew Skipsey of Deloitte UK analyse the use of profit split transfer pricing methods in the rapidly evolving banking and commodity trading businesses. ....

Profit Shifting , Pricing Guidelines , Transfer Pricing Guidelines , Frank Act ,

The shifting tides of TP: a closer look at tax controversy driving legislative changes

Christine Ramsay and Samer Wani of Deloitte Canada and Subhabrata Dasgupta of Deloitte Malaysia highlight significant legislative developments in several jurisdictions as the world strives to keep pace with the OECD s Transfer Pricing Guidelines. ....

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The banking sector - taking the TP pulse on regulation and transformation

Ralf Heussner of Deloitte Germany, Priscilla Ratilal of Deloitte Australia and Anna Lam of Deloitte UK examine the latest market and regulatory developments in the banking sector and their TP impact. ....

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The Italian Supreme Court rules on preferring the "internal CUP method" over the "external CUP method"

Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners analyse the recent ruling that clarifies the most appropriate TP method for determining the arm’s length principle. ....

Italian Revenue Agency , Revenue Agency , Italian Supreme Court , Pricing Guidelines , Transfer Pricing Guidelines , Presidential Decree ,