In addition to a higher proportion of M&A transactions that implicate multiple jurisdictions, taxing authorities worldwide have become more sophisticated in their search for revenues and often assert transfer pricing issues in the face of otherwise technically sound transaction structures. For these reasons, transfer pricing issues are front and center in the minds of the Firm's tax practitioners focused on M&A transactions. This article discusses the reasons why transfer pricing issues have become more prominent in M&A transactions in recent years.
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