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Cyprus: OECD Reshapes Transfer Pricing and Treaty Benefits
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Cyprus: OECD Reshapes Transfer Pricing and Treaty Benefits
The OECD’s 2025 update to the Model Tax Convention Commentary on Article 9 strengthens the link between tax treaties and the accurate delineation principles contained in Chapter X of the OECD Transfer Pricing Guidelines, with important implications for multinational groups using cross-border debt financing.
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