“Deadlines to Preserve Taxpayer Rights to Request Competent Authority Assistance to Relieve Double Taxation”
Source: Deloitte (US) Global Transfer Pricing Alert 2017-045 18 October 2017
“Transfer pricing continues to be the top enforcement priority of tax authorities around the world, and one of the major risks for many multinationals. With foreign tax authorities aggressively asserting transfer pricing deficiencies, many taxpayers are receiving proposed adjustments regarding intercompany transactions. For this reason, it is imperative that taxpayers understand the actions required to preserve the right to request competent authority assistance to relieve double taxation.”
This informative Transfer Pricing Alert summarise the process for preserving Competent Authority assistance to relieve double taxation and lists the notification deadlines for US Treaty Partners.