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Outsourcing agreements – between JVs and services deals

Outsourcing agreements are always a new adventure and trying to find the best contractual arrangement is not easy.  And this task is even harder in outsourcing agreements where the supplier provides a large part of the services and licenses necessary to run the business usually on the basis of a profit sharing arrangement.  This situation might lead to relevant tax related risks because of the willingness of the supplier to control the business.