Abstract
High profitability, worldwide physical presence and strong leverage on intangibles make the luxury fashion businesses ideal targets for transfer pricing scrutiny. The industry dynamics are rapidly transforming, with digital revolution and younger customer base being the main factors. New transfer pricing issues are already adding to the existing ones: progressive lack of comparables due to expansion along the supply chain, double taxation remedies still costly and slow, increasing interest in APAs as the only viable solution to secure transfer pricing risk.
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