Transfer Pricing (21st edition) (March 2021)

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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

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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 by EY Russia

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

Evgenia Veter of EY outlines the Federal Tax Service’s guidelines on taxing intra-group services in Russia and considers its potential impact for businesses and taxpayers.

Evgenia Veter, March 24 2021
Sponsored by Skeppsbron Skatt

OECD TP guidelines in clash with recent VAT developments in Sweden

Mikael Jacobsen and Janina Hägg of Skeppsbron Skatt describe how businesses in Sweden find themselves at a crossroad between complying with Swedish VAT regulation, and following the OECD TP Guidelines.

Janina Hägg, March 24 2021

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