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Alberto Pluviano Publications
Transfer Pricing in the distribution chain: the remuneration of “marketing intangibles”
Alberto Pluviano
Alberto Pluviano and co-author, Alberto Calori of Studio Bracchetti Calori e Associati, analyze the remuneration of distribution activities in an article entitled “Transfer Price nella catena distributiva: la remunerazione dei ...The French Government Report on Taxation of the Digital Economy
Alberto Pluviano
In this article Alberto Pluviano summarizes the key elements of a report published by the French government on taxation issues of the digital economy, the possible impact on the ongoing ...France and Italy Documentation Requirements--A Comparative View
Alberto Pluviano
Both Italy and France have recently finalised their transfer pricing documentation regulations by issuing administrative instructions on, respectively, December 15, and December 23, 2010.The two countries’ regulations differ quite significantly ...Insights: Transfer Pricing: February 2012
The February 2012 edition of this newsletter includes articles written by:Alberto PluvianoBrad Rolph This issue also features seven upcoming events, summarizes news from around the world, and highlights two industry awards ...OECD transfer pricing guidelines
Alberto Pluviano, Gerben Weistra
The OECD Council approved the 2010 version of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the Guidelines) on July 22, 2010. Authors Alberto Pluviano and Gerben Weistra ...Transfer Pricing Documentation - General Framework and Practical Aspects
Alberto Pluviano
The article illustrates the general framework and discusses the key practical aspects related to building a transfer pricing documentation package; it also links the practical conclusions derived from international experience ...CRA Insights: Transfer Pricing: February 2011
This issue highlights Italy's and France's finalization of transfer documentation regulations, the upholding of the decision in the GE Capital Canada case, and Schedule UTP and the IRS’s policy of restraint as well as ...CRA Insights: Transfer Pricing: October 2010
CRA Insights: Transfer Pricing: October 2010Nicole BordeleauGuy KerschKathrine KimballAlberto PluvianoPerry Urken
Brian VincentGerben Weistra This issue of CRA Insights: Transfer Pricing features:"OECD Transfer Pricing Guidelines" "Business Restructuring in Luxembourg" "A summary of the ATO’s Draft ...CRA Insights: Transfer Pricing: June 2010
Molly Minnear, Emily Radel, Alberto Pluviano, Anna Lam, Brian Vincent
The Ballentine Barbera Group of Charles River Associates welcomes two new principals and a senior consultant "Advance pricing agreements and merger and acquisition activity: A strategy for mitigating post-integration risk" "Beyond the ...
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