Harmonising a company’s transfer pricing documentation with customs requirements has always been a contentious issue because of the inconsistencies between the two regimes. David Grace, Emin Toro and Mateo Caballero from Covington & Burling explain how taxpayers can make this process easier.
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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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The court emphasised that TP analysis must adhere to the arm's-length principle, be based on the specific facts of each transaction and comply with domestic regulations, one expert says