Over the past three decades, the expansion of world trade has been at the forefront of the economics of international trade. The term globalisation was coined and an increase in the number of cross-border or multinational firms emerged. With the expansion of multinationals seeking opportunities to increase productivity and to maximise profits, they realised the differences in corporate tax rates could have a tremendous impact on the company’s bottom line. In an attempt to reduce their worldwide tax payments, one area of focus was on ways to structure transactions between entities within the same controlled group but located in different countries.
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