Adapting to global fragmentation: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re taking a broad view, looking at how tax and transfer pricing heads are thinking about a more fragmented and decentraized world. Also, Luxembourg posts Amount B guidelines, an Indian court slaps down tax authority arguments for taxing fees for virtually provided services, and the OECD is investigating specifics for possible MAP guidance expansion.

The days of international tax kumbaya are over, and the days of dog-eat-dog deglobalization are here.

OK, things weren’t exactly utopian before, but the sudden reversal of the globalization trend has tax ...