Taxpayers in developing markets can find it difficult to find reliable comparables to benchmark their transfer pricing. However, the UN Practical Manual on Transfer Pricing for Developing Countries demonstrates why detailed comparable transaction data is required by tax administrations in developing countries, when compared with guidance given by the OECD to member countries.
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A global tax framework may not materialise anytime soon, but a common set of principles is becoming increasingly necessary, Rudolf Winkenius also tells ITR
While pillar two can progress without the US, it won’t reach the same heights without American involvement, argues Renáta Bláhová, founding partner of BMB Partners Taxand
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