For a considerable period, transactions between related entities have been a focal point of tax authorities worldwide. A fundamental element of these transactions involves to the precise determination of the market value of goods and services transferred within...
I. General Information The biggest challenge of transfer pricing is to find appropriate prices for cross-border transactions between associated enterprises. In order to determine, which transfer price can be considered appropriate, systematic guidelines are required...
Thin capitalisation rules are designed to prevent companies from artificially inflating interest deductions by relying excessively on debt instead of equity, a practice that can lead to tax base erosion. In Greece, these rules are enforced through interest deduction...
This post aims to share some of the China ‘s transfer pricing regulation and practice, which includes key investigation objects of transfer pricing in China and the threshold of transfer pricing documentations in China. Key investigation objects of transfer pricing in...
Since the beginning of 2024, the regulations governing transfer pricing controls in France have undergone significant changes. Three key updates, effective as of January 1, 2024, include modifications to the threshold for mandatory transfer pricing documentation, a...
In the dynamic landscape of global business, transfer pricing documentation has become a critical component for multinational enterprises to ensure compliance with international tax regulations. Traditionally, preparing transfer pricing (TP) documentation has been a...
New procedural tax law obligations in the Dutch implementation of Pillar Two The Minimum Tax Rate Act 2024 (Wet minimumbelasting 2024), the Dutch implementation of Pillar Two (EU Directive 2022/2523), introduces a specific information obligation (informatie...
This measure is part of the international tax reform promoted by the OECD to address the tax challenges arising from the digitalisation of the economy, within the framework of the initiatives against Base Erosion and Profit Shifting (BEPS). It is part of "Pillar 2" of...
I. Transfer Pricing in Germany: Initial Situation Business processes of a globally active company are distributed worldwide due to the increasing convergence of markets. Those countries in which companies are active would understandably like to tax a portion of the...
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