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Internal Revenue Code section 482 is the U.S. Congress respond to OECD to monitor transfer pricing issues potentially committed by MNES (Multi National Entities).

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Internal Revenue Code section 482 is the U.S. Congress respond to OECD to monitor transfer pricing issues potentially committed by MNES (Multi National Entities). 3 specific transfer pricing issues facing each tax authority in different countries in the world are: O Valuation, Allocation & Proration. O Allocation, Jurisdiction & Division. Jurisdiction, Valuation & Allocation. Jurisdiction, Certification & Valuation.

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