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  • Ankit Jain

BEPS Action 8-10:Transfer Pricing

BEPS Actions 8-10 address transfer pricing guidance to ensure that transfer pricing outcomes are better aligned with value creation of the MNE group. In this regard, Actions 8-10 clarify and strengthen the existing standards, including the guidance on the application of the arm’s length principle and an approach for appropriate pricing of hard-to-value-intangibles within the arm’s length principle.





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