New member alert in Kenya!
Pride Partners International™ extends a warm welcome to its most recent member of the African region, Fortera Consulting.
Read moreGlobal association of transfer pricing and valuation consulting firms with presence in the most entrepreneurial cities around the globe.
Read moreGlobal association of transfer pricing and financial valuation consulting firms with a presence in most entrepreneurial markets around the world.
International transfer pricing is one of the most complex tax matters. PPI members are experts with proven experience in transfer pricing strategy and policy development.
PPI members have extensive experience and cooperate to quantify and present valuation analyses related to intangible assets and business entities, even in the most challenging markets.
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Pride Partners International™ is a global association of transfer pricing and financial valuation consulting firms with a presence in major cities and entrepreneurial markets around the world.
Read morePride Partners International™ is comprised of transfer pricing and valuation services experts, as well as compliance and consulting firms around the world, every one of whom has high-quality standards, strong ethical values, an entrepreneurial spirit, and a unique client-oriented approach.
Read moreBeing a Pride Partner means being part of the global elite in transfer pricing and financial valuation services.
The association offers its members the potential to establish international relationships with high-level professionals and experts in each of their different business areas while remaining actively involved in the market to which they are directed.
Read morePride Partners International™ extends a warm welcome to its most recent member of the African region, Fortera Consulting.
Read moreIn March 2023, our association provided the 2022 PPI Awards Virtual Ceremony for its members to celebrate the participation of our members in the events during the last year. We hope everyone had fun at our Virtual Reality Ceremony Hall offline.
Read moreThe PPI annual global conference was held at the Hotel Novotel Les Halles in Paris on March 7, 8, and 9, 2023. Collaborating with Intra Pricing Solutions, EFE Consulting Group, and Cápita Works. The event was focused on critical topics of interest for our transfer pricing community as well as the challenges that organizations currently face at national and regional levels, with the following approach:
Read moreAn institutional agreement was signed with the renowned multinational company Ryan and their tools of databases as Thomson Reuters, which will allow members of Pride Partners International™ to access discounts on specialized products that provide essential information to ensure better decision-making and increased efficiency.
Read morePride Partners International™ extends a warm welcome to its most recent member of the American region, TP International Advisors.
Read morePride Partners International ™ extends a warm welcome to its newest member from the Asian Pacific region, Ramasamy Chockalingam "Chock".
Read moreOn December 2022, our association offered this meeting place for members to exchange experiences and learn more about the outline of the lifting of supporting documentation on atypical circumstances in transfer pricing. Firms from Mexico, Panama, Chile, Ecuador, Costa Rica and Colombia, as well as special guests from Brazil, and Spain, were active participants.
Read moreOn November 2022, our association offered this meeting place for members to exchange experiences and learn more about the update on taxation of the digitalised economy. Firms from Cyprus, the Netherlands, Peru, Israel, Canada, Brazil, and the United States were active participants.
Read morePride Partners International ™ extends a warm welcome to its newest member from the European region, Czech Republic.
Read moreIn October 2022, our association provided a meeting point for its members to exchange experiences about the measures and innovations that their firms have taken, as well as learn about their practices and services regarding the challenges that they have assumed in each jurisdiction.
Read moreThe OECD’s Inclusive Framework has established a two-pillar strategy on Base Erosion and Profit Shifting (BEPS) to combat tax evasion, advance coherence and transparency in the international tax system, and solve tax issues through the digitalization of the economy. The BEPS project aims to ensure that major multinational corporations pay the bare minimum in global taxes.
Read moreAs a part of the ongoing BEPS 2.0 project on addressing tax challenges related to the digitalization of the economy, the OECD, on December 8, 2022, released a public consultation document discussing the main components of "Pillar One - Amount B." This document presents a new method for pricing the "baseline distribution activities" by multinational enterprises (MNEs) as per the arm's length principle. This approach aims at simplifying and streamlining the transfer pricing process for these in-country marketing and distribution activities while still ensuring that pricing is in line with the arm's length principle. This article is aimed at providing a summary of critical elements of the public consultation document.
Read moreIn the fifth and final part of a series on the introduction of corporate tax in the United Arab Emirates, Parwin Dina of Global Tax Services highlights some of the key aspects of the recently issued law.
Read moreThe CFC authorities had invited this morning eminent members of the DGI (including the new Director General of Taxes, Mr. Younes IDRISSI KAITOUNI, as well as Mr. Hassan BOULAICH, Head of the Directorate of Legislation, Studies and International Cooperation) to comment on the tax provisions recently introduced by the 2023 Finance Law during an event organized at the CFC First Tower.
Read moreOn 5 January 2023 the Cyprus Tax department (CTD) issued a circular (1/2023) which terminates the application of “safe harbours” on back-to-back financing transactions with related parties. The termination applies from 1 January 2022 onwards.
Read moreThe Brazilian government has enacted new transfer pricing (PT) legislation based on the arm's length principle, in accordance with the Organization for Economic Cooperation and Development (OECD) guidelines. The move was prompted by recent changes to the US tax code, which no longer recognizes taxes paid in Brazil as a credit due to deviations from the arm's length principle in Brazil's PT system.
Read moreFive reasons multinational enterprises should review their transfer pricing positions!
Read moreThe U.S. Tax Court in the case of Whirlpool Financial Corp. v. Commissioner, Nos. 1899/1900 upheld the Internal Revenue Service’s (IRS) decision of considering the sales income derived by Whirlpool Luxembourg from the manufacturing operations in Mexico as Foreign Base Company Sales Income (FBCSI) to the parent company in the U.S. under section 951(a). This article provides a summary of the case law.
Read moreToday Multinational organizations are facing various challenges due to stringent transfer pricing audits from the tax authorities globally. The dynamic environment adds to the pressure on MNEs to continually align their transfer pricing arrangements across jurisdictions and adapt their international taxation strategy to the developments. This article highlights six potential transfer pricing pitfalls multinational enterprises can avoid ensuring the transfer pricing principles are applied neutrally to their intercompany transactions.
Read moreRecently the U S Tax Court issued its second opinion in the case of Medtronic, Inc and Consolidated Subsidiaries vs Commissioner for determining the arm's length rate for a licensing agreement between Medtronic Inc and its foreign subsidiary, Medtronic Puerto Rico for the tax year 2005 and 2006.This article summarizes the recent U S Tax ruling and its relevance for businesses.
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