Global 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.
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In February, 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 moreIn February 2024, our association offered this meeting place for members to exchange experiences and learn more about Best Transfer Pricing for Loans and Cash Pools. Firms from Mexico, Florida, Hungary, Greece, Panama, and Spain were active participants.
Read moreIn February 2024, our association organized the first assembly of 2024 of the LATAM Regional Committee as a meeting point for its members. This committee is an advisory body of the Executive Office, constituted to promote collaboration, the organization of events, as well as networking among members of the region.
Read moreIn January 2024, our association organized the first assembly of 2024 of the EMEA Regional Committee as a meeting point for its members. This committee is an advisory body of the Executive Office, constituted to promote collaboration, the organization of events, as well as networking among members of the region.
Read morePride Partners International ™ extends a warm welcome to its newest member from the European region, Anastasia Sagianni.
Read moreIn January 2024, our association organized the first 2024 assembly of the APAC Regional Committee as a meeting point for its members. This committee is an advisory body of the Executive Office, constituted to promote collaboration, the organization of events, and networking among members of the region.
Read morePride Partners International ™, the global association of consulting firms on transfer pricing and financial valuation, is pleased to welcome a new member in the latin American region, Acesa.
Read moreIn October 2023, PPI launched the first PPI Podcast on Spotify featuring engaging discussions with our esteemed partners from around the globe—Rubeena Dina, Terence Wilhelm, Jimmie Van de Zwaan, and Jose Otero representing Dubai, France, The Netherlands, and Spain.
Read moreOn November 2023, our association offered this meeting place for members to exchange experiences and learn more about Trends and Developments in Country-by-Country reporting. Firms from Spain, The Netherlands, Singapore, Italy, Hungary, Slovenia, and Dubai, were active participants.
Read morePride Partners International ™, the global association of consulting firms on transfer pricing and financial valuation, is pleased to welcome a new member in the Asian region, Union Alpha.
Read moreAs part of the Two-Pillar solution to address the Tax Challenges arising from the digitalisation of the economy, Amount B of Pillar 1 provides for a simplified and streamlined approach to the application of the arm’s length principle to baseline marketing and distribution activities, with a particular focus on the needs of low-capacity jurisdictions (LCJ). On 19th of February, the OECD/G20 Inclusive Framework (IF) released its report.
Read moreFacts, Procedures, and the DecisionDECEMBER 2021 STATEMENT OF FACTSSAS Itron France (“Taxpayer”) (a manufacturer and distributor of water, electricity and gas meters) was the subject of a tax audit for the financial years 2012 and 2013, which resulted in an assessment. The tax authorities (“TA”) considered that the transfer pricing applied by the group had resulted in an understatement of taxable income in France and a transfer of profits to a Hong Kong-based distributor ofthe group.
Read moreAs part of the Two-Pillar solution to address the Tax Challenges arising from the digitalisation of the economy, Amount B of Pillar 1 provides for a simplified and streamlined approach to the application of the arm’s length principle to baseline marketing and distribution activities, with a particular focus on the needs of low-capacity jurisdictions (LCJ). On 19th of February, the OECD/G20 Inclusive Framework (IF) released its report.
Read moreIntroduction On 6 July 2023 the Cyprus Tax Department issued a circular (6/2023) that introduces simplification measures (simplified transfer pricing documentation and option to apply safe harbor rates) for taxpayers that are exempted from the obligation of preparing a TP Local file.
Read moreAs a member of the Transfer Pricing Specialists - TPs community, I'm thrilled to share a pivotal development from the US Internal Revenue Service. On December 19, 2023, the IRS Deputy Associate Chief Counsel (International) released a memorandum (AM 2023-008) with significant implications for multinational enterprises (MNEs) in the realm of transfer pricing.
Read moreLowering of the Documentation Threshold: Reduction of the threshold from 400 million to 150 million euros for the documentation of transfer prices, applicable to financial years starting after January 1, 2024. Increase in Fines: Fines for non-presentation of documentation increase from €10,000 to €50,000. Extension of the Limitation Period for Transfers of Intangibles: Extension from 3 to 6 years for the audit of cross-border transfers of difficult-to-value intangibles, allowing tax authorities to use post-transfer profits to assess their value.
Read moreGlobal Anti-Base Erosion or ‘’GloBE’’ rules are again going to be at the forefront of international tax this year and it is an opportune time to revisit how the rules interact with transfer pricing to avoid double taxation in case of adjustments made by Tax Authorities.
Read moreAs part of its ongoing review of transfer pricing conditions, HMRC has confirmed that “Transfer Pricing Records Regulations 2023” came into force on 9th August 2023. The new regulations largely confirm positions that we had already discussed in our previous article (link) on UK documentation but they also clarify some important additional points.
Read moreThe "Arrow" judgment delivered by the CAA of Lyon this week reminds us that if the burden of proof in terms of transfer pricing shifts more and more from the administration to the taxpayer, the service must nevertheless be careful to choose its angle of attack, specifically in the In that case, the administration had challenged the royalties paid by the French company Arrow to its parent company and its sister company established abroad under the sub-concession of IP rights relating to technical files, allowing the filing of marketing authorisations.
Read moreIn a very dense decision issued this summer, the Supreme Court upheld the transfer pricing adjustments made against ST Dupont, on the grounds that it could not produce sufficient evidence to demonstrate that the selling prices charged vis-à-vis its subsidiary located in Hong Kong were arm's length (EC 05/07/2023, 464928, St Dupont).
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