29
Jan
2021
Tax and Development briefings
A dedicated series of briefings on current projects covering the OECD's tax and development work will be open to the Inclusive Framework membership and the public.
Read MorePride Partners International
Global association of transfer pricing and valuation consulting firms with presence in the most entrepreneurial cities around the globe.
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Pride Partners International™
Global association of transfer pricing and financial valuation consulting firms with a presence in most entrepreneurial markets around the globe.
Transfer Pricing
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.
Valuation
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™
Imminent response to the global market.
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 more
How is Pride Partners International™ Conformed?
Transfer pricing and financial valuation services experts.
Pride 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.
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Why become a Pride Partner?
Being 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 more- Training and leadership development.
- Strengthened local and global interpersonal relations.
- Development of technical know-how.
- Fully personalized attention.
- Resource optimization and business opportunities.
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PPI™ Introduction
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OECD- Tackling tax avoidance and evasion
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OECD and CIAT co-operating to promote stronger tax systems and administration
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OECD- Introducing OECD’s e-learning in taxation: A revolution in the Global Relations Programme
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OECD- Eliminating Treaty Shopping
Latest news
29
Jan
2021
Tax and Development Day
A dedicated series of briefings on current projects covering the OECD's tax and development work will be open to the Inclusive Framework membership and the public.
Read More27
Jan
2021
11th meeting of the OECD/G20 Inclusive Framework on BEPS
Due to the ongoing health crisis, the 11th plenary meeting of the 137 members of the OECD/G20 Inclusive Framework on BEPS will be held virtually and open to the public, allowing a glimpse into the various international tax-related workstreams undertaken by the Inclusive Framework to date.
Read More25
Jan
2021
Taxing Energy Use for Sustainable Development: Opportunities for energy tax and subsidy reform in selected developing and emerging economies
This report presents results for 15 developing and emerging market economies. The results include data and indicators to support carbon pricing reforms in these 15 countries, and compares their macro-economic and policy context to OECD countries.
Read More22
Jan
2021
Tax and Development Case Studies
This page presents several case studies in selected countries which demonstrate how governments in developing countries are addressing tax avoidance and evasion, supported by the OECD's and Global Forum's tool and capacity building services.
Read More21
Jan
2021
OECD/G20 Inclusive Framework on BEPS to meet at plenary level on 27-28 January 2021
The OECD/G20 Inclusive Framework on BEPS will hold its biannual plenary meeting on 27-28 January 2021.
Read More21
Jan
2021
Updated guidance on tax treaties and the impact of the COVID-19 crisis
This note revisits the guidance issued by the OECD Secretariat in April 2020 on the impact of the COVID-19 pandemic on tax treaties. The guidance represents the Secretariat's views, supported by Working Party 1, on the interpretation of the provisions of tax treaties intending to provide more certainty to taxpayers during this exceptional period when those measures were applicable.
Read More19
Jan
2021
Platform for Collaboration on Tax's New Toolkit Helps Countries Implement Effective Transfer Pricing Documentation Requirements
The Platform for Collaboration on Tax, a joint initiative of IMF, OECD, UN and the World Bank, has released the final version of the Practical Toolkit to Support the Successful Implementation by Developing Countries of Effective Transfer Pricing Documentation Requirements.
Read More15
Jan
2021
Estonia deposits its instrument of ratification for the Multilateral BEPS Convention
Estonia deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (Multilateral Convention or MLI), which now covers over 1700 bilateral tax treaties, thus underlining its strong commitment to prevent the abuse of tax treaties and BEPS by multinational enterprises. For Estonia, the MLI will enter into force on 1 May 2021.
Read More14
Jan
2021
Public consultation meeting on the Reports on the Pillar One and Pillar Two Blueprints
The OECD/G20 Inclusive Framework on BEPS invites public input on the Reports on Pillar One and Pillar Two Blueprints. This public consultation meeting will focus on the key questions identified in the consultation document and raised in the written submissions received as part of the consultation process.
Read MoreLatest member articles
19
Jan
2021
Coca-Cola: Contractual terms vs economic substance
In transfer pricing analysis, which prevails: the contractual terms of a related party transaction, or the economic substance?
Read More05
Jan
2021
OECD Guidance on the TP Implications of Covid – A legal perspective
The OECD’s guidance issued on 18 December 2020 on the Transfer Pricing implications of Covid (the ‘Covid Guidance’) may not have offered up any real surprises. Certainly that seems to have been the intention, and para 5 of the Covid Guidance states that it should be regarded as an application of existing guidance, and not an expansion or extension of the 2017 Transfer Pricing Guidelines.
Read More04
Jan
2021
Top secret to avoid transfer pricing dispute – Works every time
Transfer pricing is an effective tool to allocate profits across the value chain globally so that every tax jurisdiction in the value chain is remunerated with an equitable and fair distribution of taxes. This article is not for the corporations that believe in transfer mispricing and adopts tax avoidance strategies. The beneficiaries of this piece of knowledge and experience should be the corporations that believe in fair practices but get caught in the tax litigations due to reasons other than transfer mispricing.
Read More22
Dec
2020
How to set transfer price in COVID – The OECD way (18 key takeaway)
On 18th December 2020, OECD issued a guidance on transfer pricing implications during COVID 19. The guidance is the consensus view of 137 members of the Inclusive Framework of BEPS regarding application of OECD Transfer pricing Guidelines (TPG). The guidance is meant for the taxpayers as well as tax administrations, that would help both of them in their process of price fixation and transfer pricing assessments respective for the period of pandemic.
Read More21
Dec
2020
Sharpening the Axe – Transfer Pricing Agreements
Abraham Lincoln quoted as saying “ Give me six hours to chop down a tree and I will spend the first four sharpening the axe. ” An axe is a strength multiplier. You can be the strongest lumberjack in the world, but with a dull axe, you are no good than a 5-year-old.
Read More15
Dec
2020
TP functions vs legal transactions
One of the perennial challenges in the legal implementation of transfer pricing policies is reconciling differing perspectives: those of functional analysis on the one hand, and legal rights and obligations on the other.
Read More11
Dec
2020
Transfer Pricing Agreements
A multinational group is a family of group entities working together in a globalized economy. Group entities that thrive on the same values and vision across the globe. Such a multinational group undertakes business in various tax jurisdictions, either as a profit center or as a cost center/ back office support for the group. The document that keeps the transactions and activities of such a multinational group together is called as an Inter Corporate Agreement (ICA) or Transfer Pricing Agreement (TPA). Such a document could be considered as an eye for the dealings undertaken by the group within its member companies. Let us understand certain basic aspects of the ICA.
Read More01
Dec
2020
Price setting vs outcome testing in Germany and Poland
The following article has been kindly contributed by Dr Harold McClure, a New-York based economist who has over 25 years of transfer pricing experience. Dr. McClure received his Ph.D. in economics from Vanderbilt University in 1983 and began his transfer pricing career at the IRS. He later worked at several Big 4 accounting firms, Law and Economics Consulting Group, and was the lead economist in Thomson Reuters’ transfer pricing practice.
Read More10
Nov
2020
The two types of profit split arrangements in transfer pricing
In commercial relationships as in intra-group structures, there are two types of profit split arrangements.
Read More12
Oct
2020
Building something that stands up
Apparently, the IRS believes that the quality of transfer pricing documentation may have declined. (See its FAQ guidance issued in April this year.) They believed it necessary to remind practitioners that TP documentation needs to be consistent with risk allocation in intercompany agreements.
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