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Transfer Pricing
  Jun 26, 2023
CARA Société d'Avocats

A Small Tax Revolution With a Chocolate Taste

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...
Transfer Pricing
  Jun 26, 2023
TPS

Draft legislation presented to Dutch parliament to adopt Pillar II

Following the public consultation initiated on 24 October 2022, on 31 May 2023 the government presented draft legislation to the Dutc...
Transfer Pricing
  Jun 26, 2023
TPS

Brazil finally adopts arm’s length principle

The introduction of significant transfer pricing developments in Brazil that will have a significant impact on MNEs with a business p...
Transfer Pricing
  Jun 13, 2023
TPS

The Minister of Public Accounts has just announced a powerful set of measures to combat tax and customs fraud.

These measures, set to be included in the Finance Bill for 2024, are poised to strengthen our financial ecosystem and ensure fairness in t...
Transfer Pricing
  Jun 13, 2023
TPS

Exciting news in Brazil!

The Senate has recently approved a Provisional Measure that introduces new rules on transfer pricing in Brazil. This significant step alig...
Transfer Pricing
  Mar 29, 2023
Global Tax Services

Transfer Pricing regime in the United Arab Emirates

Article 34(1) of the Federal Decree of taxation of corporates and businesses provides that transactions between related parties must be un...
United Arab Emirate
  Feb 07, 2023
Global Tax Services

Corporate Tax in the UAE—Are You Ready? (Part 5)

In the fifth and final part of a series on the introduction of corporate tax in the United Arab Emirates, Parwin Dina of Global Tax Servic...
Transfer Pricing
  Feb 07, 2023
PremioConsult Limited

Transfer Pricing (TP) “safe harbours” on related party financing transactions abolished.

On 5 January 2023 the Cyprus Tax department (CTD) issued a circular (1/2023) which terminates the application of “safe harbours” on back-t...
Transfer Pricing
  Feb 07, 2023
TPS

Brazil adapts its TP standards to the OECD

The Brazilian government has enacted new transfer pricing (PT) legislation based on the arm's length principle, in accordance with the Org...
Intercompany Agreements
  Dec 30, 2022
LCN Legal

What is a “swimming pool” clause in an intercompany agreement?

A ‘swimming pool’ clause may be appropriate in a Transfer Pricing context whenever there is an intercompany supply of services, and the ac...
Intercompany Agreements
  Dec 30, 2022
LCN Legal

What is ‘recourse’ in intercompany agreements?

The concept of ‘recourse’ is key to understanding risk allocation in intercompany agreements.

United Arab Emirate
  Nov 14, 2022
Global Tax Services

Corporate Tax in the UAE – Are you ready? (Part 3)

In the third part of a series, Parwin Dina of Global Tax Services considers some interesting aspects of the upcoming corporate income tax...