The double taxation risks in cross border restructuring
September 12, 2011
Ralph Cunningham TPW
The OECD project on the transfer pricing aspects of business restructuring has clarified a lot of the issues around the topic since it began in 2005, but uncertainties still remain, the annual congress of the International Fiscal Association (IFA) was told on Monday.
The project ended in the adoption of a new chapter 9 in the OECD's transfer pricing guidelines in July 2010.
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