Transfer Pricing 2025

Contents

INTRODUCTION Contributed by Paolo Ludovici, Marlinda Gianfrate, Luca Tortorella and Angelica Masciulli, Gatti Pavesi Bianchi Ludovici p.5 AUSTRALIA Law and Practice p.12 Contributed by King & Wood Mallesons Trends and Developments p.22 Contributed by King & Wood Mallesons AUSTRIA Law and Practice p.27 Contributed by Grant Thornton Austria Trends and Developments p.43 Contributed by Grant Thornton Austria BELGIUM Law and Practice p.50 Contributed by Loyens & Loeff Trends and Developments p.74 Contributed by Loyens & Loeff BRAZIL Law and Practice p.82 Contributed by William Freire Advogados Trends and Developments p.108 Contributed by Machado Meyer Advogados

INDIA Law and Practice p.165 Contributed by AZB & Partners Trends and Developments p.188 Contributed by BMR Legal

ITALY Law and Practice p.198

Contributed by Maisto e Associati Trends and Developments p.222 Contributed by Gatti Pavesi Bianchi Ludovici

LUXEMBOURG Law and Practice p.230

Contributed by ATOZ Tax Advisers Trends and Developments p.250 Contributed by Loyens & Loeff NETHERLANDS Law and Practice p.259 Contributed by Borgen Tax Trends and Developments p.279 Contributed by Loyens & Loeff

PERU Law and Practice p.289 Contributed by +Value SOUTH KOREA Law and Practice p.309 Contributed by Lee & Ko

CYPRUS Law and Practice p.117 Contributed by Kinanis LLC Trends and Developments p.131 Contributed by Kinanis LLC

Trends and Developments p.333 Contributed by Yoon & Yang LLC SWITZERLAND Law and Practice p.340 Contributed by Tax Partner AG Trends and Developments p.365 Contributed by Tax Partner AG

FRANCE Law and Practice p.137

Contributed by Baker McKenzie Trends and Developments p.159 Contributed by Baker McKenzie

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