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Transfer Pricing for Funds: Dealing with ‘People Functions’ and Challenges from Tax Authorities

Updated: Oct 9, 2023

By: Steef Huibregtse, Casrsten Schmid, Margie van der Valk and Avisha Sood.


Aligning substance with value creation and the extent to which people functions can be

a factor in the analysis has become heated topics for debate under the Organization for

Economic Cooperation and Development’s plan to combat base erosion. In this context, the

authors consider how structures set up by private equity funds have come under scrutiny

from tax authorities.


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