Despite trends towards simplification and clarification of rules, transfer pricing has become more complicated and the trend is leaning towards more uncertainty. Thomas Borstell and Loren Ponds, of Ernst & Young’s global transfer pricing team, explain how taxpayers can manage their transfer pricing risk in the changing environment.
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The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR
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