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2min chapter
Pillar Two Safe Harbors: The CbCR journey
Cross-border Tax Talks
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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Discover
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Listen to the best highlights from the podcasts you love and dive into the full episode