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By Xavier SOTILLOS JAIME, Serena PICARIELLO Luca DERQUI, Deloitte Luxembourg*
Transfer pricing remains a key focus area for tax authorities, which scrutinize intra-group transactions and the allocation of profits across jurisdictions. In this context, transfer pricing adjustments may lead to economic double taxation, where the same income is taxed twice because an upward adjustment in one country is not matched by a corresponding downward adjustment in the other. Mutual Agreement Procedures (MAPs) constitute an important mechanism for the elimination of double taxation, as they seek to align the transfer pricing treatment between jurisdictions.
Recent OECD MAP statistics indicate a general...
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