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Don't ‘B’ left Behind how companies need to prepare for amount B by Kartikeya Singh... [et al.]

Contributor(s): Singh, Kartikeya.
Material type: ArticleArticlePublisher: 2024Subject(s): AMOUNT B (PRIMER PILAR, OCDE) | FISCALIDAD INTERNACIONAL | PRECIOS DE TRANSFERENCIA | ORGANIZACION DE COOPERACION Y DESARROLLO ECONOMICO In: Tax Notes International v. 116, n. 3, October 21 2024, p. 357-369Summary: Kartikeya Singh is a principal, Anthony Tufo is a senior associate, Shubhana Sattar is a senior manager, and Marco Fiaccadori is a principal in the transfer pricing practice of PricewaterhouseCoopers’ Washington National Tax Services. The authors thank Lili Kazemi for her contributions to this article and Pat Brown for his review and comments. In this article, the authors explain the OECD inclusive framework’s amount B and the large effect it is likely to have on transfer pricing. They analyze the ways in which multinational enterprises can prepare for the various iterations that could arise as jurisdictions choose how to react to amount B. The views expressed herein are solely those of the authors and do not necessarily reflect those of PwC. All errors and views are those of the authors and should not be ascribed to PwC or any other person.
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Kartikeya Singh is a principal, Anthony Tufo is a senior associate, Shubhana Sattar is a senior manager, and Marco Fiaccadori is a principal in the transfer pricing practice of PricewaterhouseCoopers’ Washington National Tax Services. The authors thank Lili Kazemi for her contributions to this article and Pat Brown for his review and comments. In this article, the authors explain the OECD inclusive framework’s amount B and the large effect it is likely to have on transfer pricing. They analyze the ways in which multinational enterprises can prepare for the various iterations that could arise as jurisdictions choose how to react to amount B. The views expressed herein are solely those of the authors and do not necessarily reflect those of PwC. All errors and views are those of the authors and should not be ascribed to PwC or any other person.

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