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...
China Transfer Pricing Siginificant Rules You Need To Know
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...
Changes in Transfer Pricing Control Regulations for Related Entities in France
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...
Optimising Transfer Pricing Documentation with Cutting-Edge Software
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...
Dutch Information Obligations and the Burden of Proof
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...
Global Minimum Tax For Large Companies In Spain
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...
Significant Tightening of Transfer Pricing Rules in Germany
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...
Transfer Pricing Policy. An important consideration in intercompany transactions
Considering the global economy and the increase in the international requirements due to the constant introduction of new regulations, transfer pricing documentation has become an important tax topic calling for specific strategies associated with the growing number...
EU Transfer Pricing Directive: Harmonising Regulations
On 12 September 2023, the European Commission released a proposal for The EU Transfer Pricing Directive (TP Directive), which seeks to guarantee that all Member States implement consistent transfer pricing legislation and procedures for overseeing transfer pricing and...