CRA Principal, Alberto Pluviano, reviews a report published by the French Ministry of Finance that analyzes the technical issues related to transfer pricing regulation in the French system compared with other countries and proposes new measures that would tighten the French transfer pricing regulations. The report also includes comments regarding permanent establishment issues.
Who bore the tariff burden? Economics of IEEPA refund disputes
The refund question sits at the intersection of customs procedure, administrative law, but also economics, and resolution will likely vary significantly across...