



What are the transfer pricing implications of the cessation of business activities by a related entity? How are the tax consequences of the termination of intercompany agreements determined?
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what is a non arm's length transaction
- What are the transfer pricing considerations for transactions involving the provision of management oversight and strategic direction between related entities? How should the fees for related-party management oversight and strategic direction be determined under the arm's length principle?
- How does a non-arm's length transaction differ from an arm's length transaction? Who are the typical parties involved in a non-arm's length transaction?
- How can simultaneous tax examinations help resolve transfer pricing issues in non-arm's length transactions? What are the recent trends in transfer pricing litigation related to non-arm's length transactions?
- What are the different interpretations and applications of the arm's length principle by tax authorities globally? How can a multinational enterprise navigate the complexities of diverse transfer pricing rules across different jurisdictions?
- How do tax authorities evaluate the benefit test for intercompany services? What are the different methods for allocating costs in shared service arrangements between related parties?
- What are the transfer pricing implications of transactions conducted through trusts or foundations involving related parties? How is the arm's length principle applied in the context of partnerships with related partners?
- What are the best practices for managing global transfer pricing risks in a multinational organization?
- How are intercompany dividends treated in the context of non-arm's length relationships?
- What are the transfer pricing considerations for transactions involving the sharing of employees between related entities? How should the compensation for shared employees between related parties be determined under the arm's length principle?
- What are the record-keeping requirements for non-arm's length transactions in various jurisdictions? How long should transfer pricing documentation be retained?
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