Location saving is a hot issue in developing countries. Yin Chao, who speacialises in transfer pricing at Siemens in China, and Yin Shuping, who is an associate professor at Guangdong Polytechnique Normal University, explain China’s perspective on the transfer pricing aspects of location saving on contract R&D.
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Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
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