Multinationals face heightened interest in their tax and transfer pricing positions. No longer just of interest to tax authorities, corporate tax positions have moved up the government and public agenda.
The arm’s length standard, the historic backbone of price-setting for intercompany transactions, is under attack. An increase in profit splits is expected. Tax departments are focused on substance, having the right facts to support tax positions, and managing their permanent establishments.
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Transfer Pricing, PwC US