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Pillar Two Safe Harbors: The CbCR journey

Cross-border Tax Talks

CHAPTER

Refunds, Amendments, and Transfer Pricing Implications

The lack of mechanism for refunds and amendments in transfer pricing audits is discussed, leading to a prospective adjustment approach. The implications of transfer pricing adjustments on minimum tax payments and the importance of utilizing bilateral APAs to avoid future adjustments and minimize tax implications are emphasized.

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