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

- Mar 9, 2015
- 1 min read
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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