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 globe.
International transfer pricing is one of the most complicated tax issues. PPI members are experts with proven experience with transfer pricing strategy and policy development.
PPI members have extensive experience and cooperate in quantifying and presenting valuation analyses related to intangible assets or business entities, even in 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 most entrepreneurial markets around the globe.
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 which has high quality standards, strong ethical values, a strong entrepreneurial spirit, and a unique client-oriented approach.
Read moreBeing a Pride Partner means being a part of the elite world of transfer pricing and financial valuation services.
The association offers its members the potential to establish international connectivity with high level professionals and experts in each of its different business areas, while remaining actively involved in the market to which they are directed.
Read moreNew data released today, provides aggregated information on the global tax and economic activities of nearly 4,000 multinational enterprise (MNE) groups headquartered in 26 jurisdictions and operating across more than 100 jurisdictions worldwide.
Read MoreToday, Oman deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) with the OECD's Secretary-General, therewith underlining its strong commitment to prevent the abuse of tax treaties and BEPS by multinational enterprises. For Oman, the MLI enters into force on 1 November 2020.
Read MoreThe FTA today released a report on reputational risk management, highlighting its importance for protecting and enhancing tax compliance, including in the COVID-19 environment. The report, led by the Canada Revenue Agency and the FTA's Enterprise Risk Management Community of Interest, sets out the key considerations for developing and improving reputational risk management practices within tax administrations.
Read MoreToday, the OECD has released a new global tax reporting framework, the Model Reporting Rules for Digital Platforms in the Sharing and Gig Economy ("MRDP"). Under the MRDP, digital platforms are required to collect information on the income realised by those offering accommodation, transport and personal services through platforms and to report the information to tax authorities.
Read MoreHow do corporate tax levels compare across countries? What factors are driving the variation in corporate tax burdens seen worldwide? How important are corporate tax revenues as a percentage of total revenues, on a country-by-country basis?
Read MoreEducation investment should be a priority post-COVID-19 to improve education outcomes, and increase incomes and tax revenue.
Read MoreThe international community continues making tremendous progress in the fight against offshore tax evasion, as implementation of innovative transparency standards by the Global Forum on Transparency and Exchange of Information for Tax Purposes moves countries ever closer to the goal of eradicating banking secrecy for tax purposes.
Read MoreLatest data on tax policy measures taken by governments so far in response to the coronavirus pandemic.
Read MoreThe Platform for Collaboration on Tax (PCT) – a joint initiative of the IMF, OECD, UN and World Bank Group – is seeking feedback from the public on a draft toolkit designed to help developing countries build capacity in tax treaty negotiations.
Read MoreTax Transparency in Africa 2020, launched today as part of the Africa Initiative, depicts the state of play for 32 African Union Member States, members of the Initiative and three non-members. It shows the progress achieved on the two cornerstones of the Initiative: (i) raising political awareness and commitment, and (ii) developing capacities in tax transparency and exchange of information (EOI).
Read MoreThe concept of Equalisation Levy was coined in the BEPS Action plan 1, suggested by the OECD, which gained immediate popularity amidst the global powers, who were looking for an answer for a long time for the taxation on the income earned by the companies using the digital platforms. As per the Action plan 1, “A non-resident having Significant Economic Presence (SEP) in a country could be taxed through equalisation levy”, is the principle that was laid down before applying the levy. Hence, a SEP plays a very crucial role in implementation of such a levy.
Read MoreAs some of you may already know, over the past few months we have been working closely with Adjoint Inc; a market leader in digitising corporate cash management services. Combining our legal expertise in intercompany agreements with Adjoint’s real time treasury provision, we have collaborated to create a novel and holistic offering for MNE’s which we discussed in our recently published article, The Digital CFO: LCN Legal and Adjoint join forces to help digital acceleration by Corporate CFOs.
Read MoreIt’s funny how it often seems so much easier to see the potential in someone else, than it is to see it in yourself.
Read MoreLa thématique des règlements des différends en droit fiscal international, outre le fait de renfermer un bon sujet de thèse, se pose comme une question fondamentale dans nos environnements contemporains. Peut-on encore en effet seulement aborder la fiscalité dans un cadre purement domestique, en la soustrayant à toute influence internationale ? Le point d’interrogation qui ponctue cette dernière phrase n’est que pièce rapportée, tant la réponse transpire déjà dans la question. Car sans être nécessairement fiscaliste, tout juriste (au sens large et noble du terme) sait désormais que nos normes sont pour la plupart influencées, voire directement inspirées de sources externes, qu’il s’agisse du droit communautaire, du droit conventionnel, ou encore des travaux d’organismes qui font autorité, à l’instar de l’OCDE ou de l’OMC.
Read MoreNotre article pourrait commencer comme une histoire belge : « deux fiscalistes entrent dans une pièce, l’un français, l’autre belge ». Malheureusement, le vent de réformes que souffle l’OCDE depuis l’entame de son projet dit « BEPS » a fait taire les rieurs. L’heure est désormais à l’analyse et l’anticipation, pas à la plaisanterie. Il faut bien admettre : on ne badine pas avec les redressements fiscaux susceptibles de mettre à bas un modèle économique entier, fondés sur des concepts désormais largement partagés par les administrations fiscales de tout pays. Même les îles Cayman y adhèrent. La blague !
Read MoreUntil recently, we at LCN Legal weren’t aware that insurance was available in relation to transfer pricing risks. We thought you would be interested to read the following article, which was kindly contributed by Paul Dickinson, Head of Tax (International) at Themis, an underwriting agency gaining significant traction in the M&A insurance market owing to its experienced team. Themis seeks to position itself as the partner of choice for the global M&A community by offering a broad array of transaction solutions. In the case of Tax, this includes an ability to work on more complex and structured risks, such as those which involve accounting or valuation issues.
Read MoreLast week, we were asked by the European management team of a substantial multinational group to advise on a very common scenario in the current environment – a request by made by the overseas parent company to ‘repatriate’ cash, by way of loan. The key issue was whether the directors of the European subsidiaries involved could properly approve the request and grant a loan of ‘surplus cash’ to the parent entity, and what ‘surplus cash’ actually meant in this context.
Read MoreI thought you might be interested in a question we received last week from an international tax adviser. I’ve set out the question and our answer below.
Read MoreThe more complicated a decision is, the more important it is to express what’s happening clearly and succinctly.
Read MoreA short guide for transfer pricing and tax professionals on force majeure clauses in intercompany agreements and other key legal points to consider when revising transfer pricing policies in response to COVID-19
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