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The SNF case in Australia revealed that in Australia a court could interpret domestic transfer pricing rules … differently from those in Australia's tax treaties. In particular, the court rejected the use of OECD transfer pricing guidelines …
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This paper analyzes transfer pricing incentives under a destination-based and an origin-based VAT system. While a switch to the origin-based VAT may moderate or reinforce the incentive for transfer pricing induced by income tax differentials, we show that in the case of the EU this switch tends...
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The objective of this paper is to look into the probability that, given the choice, corporate groups would opt for taxation on a consolidated basis. Consolidation would allow them to offset losses crossborder but remove the opportunity to exploit international tax-rate differentials between...
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