


How can competent authority procedures be used to resolve cross-border transfer pricing disputes related to non-arm's length transactions?
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what is a non arm's length transaction
- What role do internal controls play in ensuring compliance with transfer pricing regulations for non-arm's length transactions?
- What are the transfer pricing considerations for transactions involving controlled foreign corporations (CFCs)? How do CFC rules interact with transfer pricing regulations?
- What are the transfer pricing considerations for transactions involving the use of artificial intelligence (AI) and machine learning (ML) technologies by related parties?
- How is the value of goodwill determined in related-party transfer transactions?
- What types of training and awareness programs can help employees understand the importance of arm's length pricing in related-party transactions?
- What are the transfer pricing implications of sale and leaseback transactions between related parties?
- How should the fees for related-party legal services be determined under the arm's length principle? What are the transfer pricing considerations for transactions involving the provision of accounting services between related entities?
- What are the roles and responsibilities of different departments within a company in managing transfer pricing risks for non-arm's length transactions? How can a company's tax department collaborate with its finance, legal, and operations teams to ensure transfer pricing compliance?
- What are the challenges in determining the arm's length value of marketing intangibles in non-arm's length transactions?
- What are the common mistakes companies make in pricing non-arm's length transactions? How can companies improve their processes for determining and documenting arm's length pricing?
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