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The introduction of significant transfer pricing developments in Brazil that will have a significant impact on MNEs with a business p...
These measures, set to be included in the Finance Bill for 2024, are poised to strengthen our financial ecosystem and ensure fairness in t...
The Senate has recently approved a Provisional Measure that introduces new rules on transfer pricing in Brazil. This significant step alig...
Article 34(1) of the Federal Decree of taxation of corporates and businesses provides that transactions between related parties must be un...
On 5 January 2023 the Cyprus Tax department (CTD) issued a circular (1/2023) which terminates the application of “safe harbours” on back-t...
The Brazilian government has enacted new transfer pricing (PT) legislation based on the arm's length principle, in accordance with the Org...
For regulated groups such as those in the financial services sector, regulatory considerations usually ‘trump’ transfer pricing optimisati...
We often get asked whether it is legally possible to backdate intercompany agreements. (Answer: it depends.) But what about backdating of tr...
By Rubeena Dina, Partner at Global Tax Services, UAE and Director at GTS Africa, Mauritius and Aniruddha Saha, transfer pricing special...
We hope that you found our recent analysis of the BlackRock decision to be thought-provoking and useful. This concluded that while the j...
Sometimes, expressions used in transfer pricing reports are so vague that they may conceal more than they reveal. One example is the term 'm...
As 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...
