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The CFC authorities had invited this morning eminent members of the DGI (including the new Director General of Taxes, Mr. Younes IDRISSI K...
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...
Five reasons multinational enterprises should review their transfer pricing positions!
The U.S. Tax Court in the case of Whirlpool Financial Corp. v. Commissioner, Nos. 1899/1900 upheld the Internal Revenue Service’s (IRS)...
Today Multinational organizations are facing various challenges due to stringent transfer pricing audits from the tax authorities global...
Recently the U S Tax Court issued its second opinion in the case of Medtronic, Inc and Consolidated Subsidiaries vs Commissioner for det...
In recent years, transfer pricing audits have become more common in the United States, with the Internal Revenue Service (IRS) taking a...
Organisation for Economic Co-operation and Development (OECD) published the sixth annual progress report of the OECD/G20 Inclusive Framewo...
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...
