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As part of the Two-Pillar solution to address the Tax Challenges arising from the digitalisation of the economy, Amount B of Pillar 1 prov...
Introduction On 6 July 2023 the Cyprus Tax Department issued a circular (6/2023) that introduces simplification measures (simplified tra...
As a member of the Transfer Pricing Specialists - TPs community, I'm thrilled to share a pivotal development from the US Internal Revenue...
Lowering of the Documentation Threshold: Reduction of the threshold from 400 million to 150 million euros for the documentation of transfe...
Global Anti-Base Erosion or ‘’GloBE’’ rules are again going to be at the forefront of international tax this year and it is an opportune ti...
As part of its ongoing review of transfer pricing conditions, HMRC has confirmed that “Transfer Pricing Records Regulations 2023” came into...
The "Arrow" judgment delivered by the CAA of Lyon this week reminds us that if the burden of proof in terms of transfer pricing shifts mor...
In a very dense decision issued this summer, the Supreme Court upheld the transfer pricing adjustments made against ST Dupont, on the grou...
Introduction On 6 July 2023 the Cyprus Tax Department issued a circular (6/2023) that introduces simplification measures for taxpayers...
A small tax revolution. That's what it's all about. Small only by the low media resonance that accompanies it, when in reality, it is a re...
Following the public consultation initiated on 24 October 2022, on 31 May 2023 the government presented draft legislation to the Dutc...