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A ‘swimming pool’ clause may be appropriate in a Transfer Pricing context whenever there is an intercompany supply of services, and the ac...
The concept of ‘recourse’ is key to understanding risk allocation in intercompany agreements.
In the third part of a series, Parwin Dina of Global Tax Services considers some interesting aspects of the upcoming corporate income tax...
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...
In Part 2 of a series on the introduction of a corporate tax system in the United Arab Emirates, Parwin Dina of Global Tax Services consid...
This article is part 1 of a series of articles on the UAE corporate income tax regime. It will examine some of the implications of the prop...
We hope that you found our recent analysis of the BlackRock decision to be thought-provoking and useful. This concluded that while the j...
As you may know, every Monday we send out an e-newsletter with insights, guidance, and views on the legal implementation of transfer pri...
By Sean Neary - Direct, Neary Consulting
Sometimes, expressions used in transfer pricing reports are so vague that they may conceal more than they reveal. One example is the term 'm...