Multinational company (MNC) groups typically tend to operate in several jurisdictions with a view to make their products and services available to their customers based in several locations. Often, the overall act of delivering its products or services to its end customers is spread across a number of legal entities located in different countries to ensure delivery of products or services to customers in the most efficient manner. MNC groups use the differential tax rates available in different countries to structure the inter-company pricing within their supply chains to optimize their tax costs.

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