This article showcases the potential interplay between transfer pricing rules and the OECD’s Pillar One and Pillar Two proposals.Given their simultaneous application,conflicts between these sets of rules may arise.Th...This article showcases the potential interplay between transfer pricing rules and the OECD’s Pillar One and Pillar Two proposals.Given their simultaneous application,conflicts between these sets of rules may arise.The article also emphasizes the importance of careful consideration before implementation of these rules,including potential adjustments to domestic laws,and the need to prevent double taxation and less-than-single taxation risks through enhanced cooperation and clear communication.展开更多
文摘This article showcases the potential interplay between transfer pricing rules and the OECD’s Pillar One and Pillar Two proposals.Given their simultaneous application,conflicts between these sets of rules may arise.The article also emphasizes the importance of careful consideration before implementation of these rules,including potential adjustments to domestic laws,and the need to prevent double taxation and less-than-single taxation risks through enhanced cooperation and clear communication.
