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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In-house teams who want a balance of internal control and external expertise for pillar two should seriously consider co-sourcing models, Russell Gammon of Tax Systems argues
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