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Transfer pricing aspects intra-group services what are the open issues and what can be improved? Emanuela Bono Electrónico

By: Bono, Emanuela .

Material type: Article

ArticlePublisher: 2020Subject(s): PRECIOS DE TRANSFERENCIA

In: International Transfer Pricing Journal v. 27, n. 1, January 2020, p. 19-27Summary: The intercompany provision of services is one of the most common transactions among entities belonging to the same multinational group and it is regularly scrutinized by the tax authorities. This article looks into the international guidance on intra-group services, focusing on all the unclear and weak aspects that need to be clarified and improved in order to reduce the tax authorities? challenges and to provide the taxpayers with more certainty.

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Item type	Current location	Home library	Call number	Status	Date due	Barcode
Recursos electrónicos	IEF	IEF	ITPJ/2020/1-10 (Browse shelf)	Available		ITPJ/2020/1-10

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Previous	ITPJ/2019/6-7 Challenges to Brazilian transfer pricing rules upon accession to the OECD	ITPJ/2020/1 International Transfer Pricing Journal	ITPJ/2020/1-1 Taxing the digital economy : the OECD secretariat's new transfer pricing A-B-C and alternative courses of action	ITPJ/2020/1-10 Transfer pricing aspects intra-group services	ITPJ/2020/1-11 Dispute resolution and PE in the EU context	ITPJ/2020/1-2 Federal Court agreed with Glencore that prices for copper concentrate were arm's length	ITPJ/2020/1-3 The determination and assessment of the appropriateness of interest rates in the case of cross-border financial transactions between related parties	Next

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Resumen.

The intercompany provision of services is one of the most common transactions among entities belonging to the same multinational group and it is regularly scrutinized by the tax authorities. This article looks into the international guidance on intra-group services, focusing on all the unclear and weak aspects that need to be clarified and improved in order to reduce the tax authorities? challenges and to provide the taxpayers with more certainty.

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Transfer pricing aspects intra-group services what are the open issues and what can be improved? Emanuela Bono Electrónico

By: Bono, Emanuela.

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By: Bono, Emanuela .