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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China has deposited its instrument of approval for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention). China's instrument of approval also covers Hong Kong (China)'s bilateral tax treaties. The Convention will enter into force on 1 September 2022 for China.
Read moreOn 6 May 2022, the OECD invited public comments on the Regulated Financial Services Exclusion under Amount A of Pillar One to assist members in further refining and finalising the relevant rules. The OECD is grateful to the commentators for their input and now publishes the public comments received.
Read moreEffective tax rates on labour rebounded in 2021 as the global economy recovered and many countries began withdrawing or scaling back measures implemented in response to the COVID-19 pandemic, according to a new OECD report.
Read moreThe OECD is seeking public input on the Crypto-Asset Reporting Framework and Amendments to the Common Reporting Standard. This public consultation meeting will focus on the key questions identified in the consultation document and issues raised in the written submissions received as part of the consultation process.
Read moreThe OECD is seeking public input on the Crypto-Asset Reporting Framework and Amendments to the Common Reporting Standard. This public consultation meeting will focus on the key questions identified in the consultation document and issues raised in the written submissions received as part of the consultation process.
Read moreUzbekistan joins the international fight against tax evasion by becoming the 164th member of the Global Forum on Transparency and Exchange of Information for Tax Purposes.
Read moreSenegal has deposited its instrument of ratification for the Multilateral BEPS Convention, which now covers over 1 820 bilateral tax treaties, thus underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises. The Convention will enter into force on 1 September 2022 for Senegal.
Read moreAs part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS to implement the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, the OECD is seeking public comments on the Regulated Financial Services Exclusion under Amount A of Pillar One.
Read morePublished today during the opening session of the sixth meeting of the Punta del Este Declaration Initiative held in San José, Costa Rica, Tax Transparency in Latin America 2022 showcases the region's recent progress in tackling tax evasion and other financial crimes through transparency and exchange of information for tax purposes.
Read morePublicado hoy durante la sesión de apertura de la sexta reunión de la Iniciativa de la Declaración de Punta del Este celebrada en San José, Costa Rica, Transparencia Fiscal en América Latina 2022 muestra los recientes avances de la región en la lucha contra la evasión fiscal y otros delitos financieros a través de la transparencia y el intercambio de información con fines fiscales.
Read moreSometimes, expressions used in transfer pricing reports are so vague that they may conceal more than they reveal. One example is the term 'manufacturing services'. Here is a simplified version of a scenario that we’ve come across several times just in the last month or so.
Read moreThanks very much to everyone who attended our recent interactive webinar on the basics of intercompany agreements for financial transactions. If you missed it, you'll find a recording here.
Read moreCustomers are the driving force of any organization regardless of the sector in which it operates. Acquisition targets are often attractive on account of the customer loyalty they have built over the years as well as the data they possess about their customers. This newsletter discusses customer-related intangible assets, the various forms in which they exist as well as the methods to value them.
Read moreAs of 1 January this year, 24 of the 35 LIBOR interest rate benchmarks or ‘settings’ are no longer published.What does this mean for groups which still have intercompany loan agreements, loan notes, or cash pooling arrangements that refer to LIBOR?
Read moreBy Sean Neary, Director – Neary ConsultingThe Federal Court’s decision on 17 December 2021 in Singapore Telecom Australia Investments Pty Ltd (STAI) v Commissioner of Taxation provided a significant win for the Australian Taxation Office (ATO) with respect to the interest rate applying on international related-party loans. With the decision likely to have been core Christmas reading for many of our subscribers, this article examines the finer points of the case and the implications for taxpayers.
Read moreDans le cadre de la chronique des activités fi scales du couple OCDE/G20 (juillet 2019 à juin 2021), cetarticle est consacré aux travaux portant les prix de transfert.As part of the OECD/G20 Tax Activity Chronicle (July 2019 to June 2021), this article focuses on transferpricing.
Read moreOn 26 November 2021, Portugal’s Official Gazette published Ordinance no. 268/2021, which repeals and supersedes the previous Ordinance no. 1446-C/2001, on transfer pricing regulations and documentation requirements. The new Ordinance incorporates to the Portuguese tax legislation the latest developments introduced by the BEPS 2015 Reports into the OECD’s 2017 TP Guidelines. This alert summarises the main developments.
Read moreOn 11 November 2021, the European Parliament adopted the Public Country-by-Country Reporting Directive (PCbCR). The adoption of this Directive concludes the procedure on the introduction of specific European transparency rules and requires certain European or non-European multinational groups or independent companies to publicly disclose certain financial data broken down by country or territory. In this article, we explain what this new financial reporting obligation consists of and its differences with the current country-by-country reporting regime for tax purposes.
Read moreAt present, the United Kingdom is one of the few Western economies which does not require the companies to prepare mandatory transfer pricing (TP) documentation for tax purposes. However, in light of the latest developments, this may change in the coming months. Let us explain which will consist of the foreseen changes and how you can be prepared for them.
Read moreLast year, the US Tax Court's decision in the Coca-Cola case sent shockwaves through the tax and transfer pricing community. USD 12 billion is an eye-watering figure, so it was not surprising that a few months ago the group filed a request for the Court to reconsider the decision. The Court recently published its response, and it doesn't make happy reading for Coca-Cola or its advisers.
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