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International taxation rules for Multi-National Enterprises (MNEs) prescribe that international prices for goods and services between different subsidiaries - and therefore incomes of these subsidiaries - must be comparable to those set between independent international firms for the purpose of taxation. These rules also prescribe that risk should be accounted for in pricing and income. Since current practice of price comparisons does not yet fully allow accounting for risk, prices and in turn earnings and taxation may be distorted.
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