PROFIT ALLOCATION WITHIN MULTINATIONAL ENTERPRISES IN THE NEW DECADE | Intra Group Intangible Transactions – 21.01.2021
– Ground Breaking case law on Intangibles (egCoca Cola)
– Re-allocation of intangible related profits based on key DEMPE functions and non recognition
– The increasing use of the Profit Split Method to intangible transactions by tax administrations
– OECD Covid19 guidance and its impact on intangible transactions
– DAC6 and Intangibles
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