Mondaq Offshore: Tax > Transfer Pricing
Kinanis LLC
The Cyprus House of Representatives has recently voted a new law transposing the provisions of the European Union Anti-Tax Avoidance Directive (the "ATAD" or "Directive") into the local legislation.
WH Partners
On 24th September 2019 Starbucks won their appeal against the European Commission's decision of 2015, over a €30 million tax fine issued by the Commission. The General Court of the European Court ...
Loyens & Loeff
The EUGC appears to accept this would be the case even if there is no arm's length principle clearly laid down in domestic law.
Elias Neocleous & Co LLC
The relevant disclosure requirements must be followed by intermediaries and, in some instances, taxpayers.
Elias Neocleous & Co LLC
The report acknowledges the exit taxation rules adopted by the EU in the ATAD I and the implementation of the BEPS action plan.
McMillan LLP
The Inland Revenue Department ("IRD") issued Departmental Interpretation and Practice Notes No. 58 ("DIPN 58") on July 19, 2019 explaining the transfer pricing documentation requirements in Hong Kong.
Duff and Phelps
Consistent with the OECD framework, the IRD will also be participating in automatic exchange mechanisms designed to facilitate the exchange of CbCRs between countries.
Mayer Brown
The past few months have witnessed a number of important tax changes, which are included in this edition of the Bulletin.
KPMG Luxembourg
The last few years have seen some big changes in the corporate tax world – from ATAD1 & 2 and the EU Commission's anti-tax avoidance package to the recent US tax reform.
KPMG Luxembourg
Luxembourg has recently enacted a new intellectual property (IP) regime in line with the OECD recommendations for more tax transparency, and in June an administrative circular was issued to help clarify this regime.
ATOZ Tax Advisers
On 8 August 2019, a draft law implementing the Council Directive (EU) 2018/822 of 25 May 2018 as regards mandatory automatic exchange of information in the field of taxation in relation to reportable
ATOZ Tax Advisers
On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164
KPMG Luxembourg
Business restructurings are normally associated with a transfer of functions, risks, or assets between the entities of a group—and that means transfer pricing consequences.
KPMG Luxembourg
The EU Joint Transfer Pricing Forum (JTPF) assists and advises the European Commission on transfer pricing tax matters. Recently, it issued a report on the application of the profit-split method
Michael Kyprianou Advocates & Legal Consultants
Over the past twenty odd years, Malta has become an international hub for foreign direct investment (FDI).
Dentons
Law 52 of October 17, 2018, which regulates call centers activities for commercial use amends the tax incentives received by these companies.
STA Law Firm
The BEPS plan was launched during the 2008 financial catastrophe. The notion behind this launch was threefold (i) Firstly, to revise the international tax structure;
Schluuter Graf & Partners
Transfer Pricing (TP) is a set of rules that govern intercompany transactions and how they are treated from a corporate income tax point of view.
Clyde & Co
The UAE government has passed legislation which will change the shape of the business operating environment in the UAE for years to come.
Grant Thornton
In 2017, European Union council announced a list of non-cooperative jurisdictions for tax purposes.
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STA Law Firm
The BEPS plan was launched during the 2008 financial catastrophe. The notion behind this launch was threefold (i) Firstly, to revise the international tax structure;
WH Partners
On 24th September 2019 Starbucks won their appeal against the European Commission's decision of 2015, over a €30 million tax fine issued by the Commission. The General Court of the European Court ...
Loyens & Loeff
The EUGC appears to accept this would be the case even if there is no arm's length principle clearly laid down in domestic law.
McMillan LLP
The Inland Revenue Department ("IRD") issued Departmental Interpretation and Practice Notes No. 58 ("DIPN 58") on July 19, 2019 explaining the transfer pricing documentation requirements in Hong Kong.
KPMG Luxembourg
Luxembourg has recently enacted a new intellectual property (IP) regime in line with the OECD recommendations for more tax transparency, and in June an administrative circular was issued to help clarify this regime.
Morgan & Morgan
With the enactment of Law 57 of October 24th, 2018 that modifies Law 41 of 2007, creating a Special Regime for the Establishment and Operation of Multinational Headquarters and the Commission of Multinational Headquarters, ...
Soteris Pittas & Co LLC
In Cyprus Transfer Pricing rules are regulated by the circular issued on 30 June 2017 by the Cyprus Tax Authorities (CTA) (the "Circular") revising the transfer pricing framework for companies ...
ATOZ Tax Advisers
On 27 December 2016, the Luxembourg tax authorities released a new circular (the Circular) on the tax treatment of intra-group financing activities.
ATOZ Tax Advisers
On 8 August, the draft law (the "draft law") implementing the EU Directive 2017/952 of 29 May 2017 ("ATAD 2") amending Directive (EU) 2016/1164
Grant Thornton
In 2017, European Union council announced a list of non-cooperative jurisdictions for tax purposes.
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