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Switzerland, Singapore concede banking secrecy laws in favour of OECD BEPS project


News; Originaly posted on Saturday May 17, 2014

Switzerland and Singapore, two of the world's jurisdictions known for banking secrecy laws, have signed into an agreement that binds their respective governments to automatic information sharing of taxpayer banking information.

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Pfizer's bids for AstraZeneca - tax inversion


News; Originaly posted on Saturday May 10, 2014

If Pfizer succeeds in acquiring AstraZeneca, the merger will become one of the most expensive ones in the history of the pharmaceutical industry. But from the perspective of transfer pricing experts, Pfizer will benefit from much more than an extended patent portfolio.

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Dutch court penalises captive insurance profit shifting scheme


News; Originaly posted on Thursday May 1, 2014

The Netherlands has shown some proactive behaviour toward badly built captive insurance schemes. In this case, a court expert made use of the arm's length principle to demonstrate how an insurance firm's transactions didn't match the behaviour seen in uncontrolled transactions.

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A guide to the two-tier system documentation


News; Originaly posted on Friday April 25, 2014

How should an MNE handle the documentation burden that will come with the introduction of the OECD's master file and local file? Find out the basics here.

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Will the OECD introduce alternatives to arm's length standard?


News; Originaly posted on Friday April 18, 2014

Is the arm's length principle necessarily the only standard to the OECD's transfer pricing guidelines? Some among the OECD ranks appear to believe otherwise.

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