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Transfer Pricing Bulletin - Life after DSG?
Law-Now
15.01.2010
Over the past few months CMS has increasingly seen tax authorities in the UK, US and across Europe dissecting internal legal agreements and questioning apparently watertight attribution of risks and functions in the pricing models of group transactions. This quarter's Transfer Pricing Bulletin discusses the ongoing impact of the Special Commissioners' ruling in DSG Retail Ltd v HMRC together with a snapshot of the latest international developments in transfer pricing.
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