New member alert in USA!
Pride Partners International™ extends a warm welcome to its most recent member of the American region, TP International Advisors.
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 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 moreIn September 2022, our association organized the inaugural assembly 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 moreAn institutional agreement was signed with the renowned multinational company TaxModel, 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 newest member from the Asian Pacific region, BDB Law.
Read morePride Partners International ™ extends a warm welcome to its newest member from the European region, GHM GmbH Steuerberatungsgesellschaft.
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.
Read moreIn recent years, transfer pricing audits have become more common in the United States, with the Internal Revenue Service (IRS) taking a closer look at how companies are setting prices for transactions between related entities. The passage of the Inflation Reduction Act (PL 117 169) has further increased the IRS's ability to conduct these audits, making it more important than ever for companies to be prepared.This article will discuss the rising trend of transfer pricing audits in the US and key considerations for companies at year-end.
Read moreOrganisation for Economic Co-operation and Development (OECD) published the sixth annual progress report of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) on October 4, 2022 (the Progress Report). The Progress Report covers work on addressing the tax challenges of the digitalization of the economy (BEPS 2.0) of Inclusive Framework during the period from September 2021 to September 2022.
Read moreA ‘swimming pool’ clause may be appropriate in a Transfer Pricing context whenever there is an intercompany supply of services, and the activities carried out by the service provider may benefit more than one entity.
Read moreThe concept of ‘recourse’ is key to understanding risk allocation in intercompany agreements.
Read moreIn the third part of a series, Parwin Dina of Global Tax Services considers some interesting aspects of the upcoming corporate income tax regime from the perspective of businesses operating in the UAE mainland or the free zones.
Read moreFor regulated groups such as those in the financial services sector, regulatory considerations usually ‘trump’ transfer pricing optimisation. This is for obvious reasons: regulatory compliance is the ‘ticket to play', as non-compliance can be an existential threat.
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