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Okay baby I'm ready. Let's drive to makeout point and you can get to third base
| .,.,.,.,.,.,..,.,.,,.,.,..,>,... | 12/22/25 |
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Date: December 22nd, 2025 12:01 PM it on an alternative transfer-pricing methodology, modeling how changes to the base would affect intercompany allocations across all relevant entities, documenting the rationale for each adjustment with reference to OECD guidance, prior audit positions, and contemporaneous benchmarking studies, preparing a jurisdiction-by-jurisdiction analysis addressing potential base erosion concerns, reconciling the revised allocations to historical financial statements and tax filings, identifying any knock-on effects on withholding, VAT, and customs exposure, stress-testing the model under multiple downside scenarios, and drafting a supporting memorandum that can be lifted directly into the client’s master file and local files with minimal revision. Please also flag any assumptions that would not survive audit scrutiny in the EU and note where further factual development would be required. (http://www.autoadmit.com/thread.php?thread_id=5813096&forum_id=2:#49530817) |