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By Dinko DINEV, Partner and Ismail CANDAN, Manager, Transfer Pricing, Deloitte
In time of tumultuous financial environment, the debt investment and credit lending funds have proven to be robust players, strategically expanding amidst crises. The evolution in the economic and regulatory landscape (e.g., ATAD II) and also the recent Transfer Pricing (TP) court cases , have raised the stakes in the tax compliance process of these players. The role of TP has become crucial when it comes to substantiating the tax position of a taxpayers
The accumulation of the regulatory rules, alongside the usage of complex intra-group debt instruments in the implementation of investment structures, are putting paramount importance to the TP analysis and...
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