Consultation Solution no. 176, published by the Brazilian Federal Revenue Secretariat on July 8, 2015, made clear the tax administration’s position to require application of the PCI and Pecex methods on import and export transactions involving commodities, by determining the reliable sources of information to obtain the parameter prices for the transfer pricing calculation.
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The increasing sophistication of India’s taxation system has led to complexity across tax treaty benefits, permanent establishments, transfer pricing and more, say Sanjay Sanghvi and Ujjval Gangwal of Khaitan & Co
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