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Shiv Mahalingham, Managing Director in Duff & Phelps' European Transfer Pricing practice, provides a summary of key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months. The major changes to transfer pricing relate to OECD discussion drafts on profit splits and interest deductions that could alter the matter in which groups are financed and structured across borders.
The recent EC ruling relating to Starbucks has created a potential inconsistency between the arm's length principle and the EU state aid rules. China has formalized value chain requirements into transfer pricing regulations. In the U.S., separate bodies of law professors have set out arguments purporting that the Tax Court ruling in the Altera Corp case was wrongly decided.