Transfer Pricing (21st edition) (March 2021)

Main

Managing TP locally and globally – ITR’s TP Special Focus launched

Considering TP implications beyond the pandemic

International project management: Permanent establishments in ambush

The importance of mutual agreement procedures in international tax disputes

A five-step process for value chain analysis

OECD sets guidelines for taxpayers on the allocation of losses

DAC6 and hallmarks addressing TP in Italy

Italian TP compliance and the challenges of drafting TP documentation

COVID-19 transforms Indonesia’s digital economy and TP landscape

A closer look at TP compliance for businesses in Latin America

The taxation of intra-group services: The start of a new chapter for Russia

Strategic approaches to counter aggressive TP assessments in South Korea

OECD TP guidelines in clash with recent VAT developments in Sweden

Editorial

Managing TP locally and globally – ITR’s TP Special Focus launched

Features / Articles

Considering TP implications beyond the pandemic

International project management: Permanent establishments in ambush

The importance of mutual agreement procedures in international tax disputes

A five-step process for value chain analysis

OECD sets guidelines for taxpayers on the allocation of losses

DAC6 and hallmarks addressing TP in Italy

Italian TP compliance and the challenges of drafting TP documentation

COVID-19 transforms Indonesia’s digital economy and TP landscape

A closer look at TP compliance for businesses in Latin America

The taxation of intra-group services: The start of a new chapter for Russia

Strategic approaches to counter aggressive TP assessments in South Korea

OECD TP guidelines in clash with recent VAT developments in Sweden

Sponsored

Sponsored

Sponsored by Yulchon

Strategic approaches to counter aggressive TP assessments in South Korea

Yun Heui Cho, Yong Whan Choi, Kyu Dong Kim and Jeremy Everett of Yulchon consider the possibility of pursuing a mutual agreement procedure, a domestic appeal, or both simultaneously, in the event of transfer pricing disputes in South Korea.

Jeremy Everett, March 24, 2021
Sponsored

Sponsored by Crowe Valente/Valente Associati GEB Partners

The importance of mutual agreement procedures in international tax disputes

Federico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners provide an update on an effective and commonly used dispute resolution instrument, the mutual agreement procedure.

Alessandro Valente, March 24, 2021
Sponsored by DS Avocats

International project management: Permanent establishments in ambush

Cyril Maucour, Stéphane Gasne and Jessica Benchetrit of DS Avocats consider how the BEPS project implementation by the Multilateral Instrument exacerbates tax and employment problems related to the international mobility of employees.

Cyril Maucour, March 24, 2021

Load More