Category: Transfer pricing

Advance Pricing Agreement / Automatic Exchange of Information / Beneficial Ownership / Cyprus / G20 / OECD / Profit Shifting / Regulatory / Tax Avoidance / Tax Laws / Tax Planning / Tax Transparency / Tax treaties / Transfer pricing

Cyprus: European Mandatory Disclosure Regime (EU MDR) – A New Reality For Cypriot Intermediaries, Another Burden On Cypriot Taxpayers?

Published by: Mondaq - October 12, 2020

Mandatory disclosure rules are not something new for European Member States ("EU MS"). In fact, with the United Kingdom leading the race (from 2004), Ireland (in 2008) and then Portugal (in 2011) were the first -and only- EU MS to introduce mandatory disclosure rules in their local legislation. ... - Continue reading

Business / Jurisdiction / Multinationals / OECD / Philippines / Profit Shifting / Related party Transactions / Tax Collection / Transfer pricing

Enhanced transfer pricing regime amidst the pandemic

Posted On: August 31, 2020

Globally, the coronavirus disease 2019 (Covid-19) pandemic is requiring governments to design and implement strategies to cope with the deepening impact of the virus. They are introducing measures to cushion the blow from the economic downturn, such as drawing from reserves and intensifying tax collection efforts. As entire countries and… – Continue reading

EU / Forms / OECD / Revenue / Sweden / Transfer pricing

Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere

Posted On: February 11, 2020

The Swedish tax agency has adjusted the taxable income for the PUMA Group’s Swedish distributor, Puma Nordic AB, concluding that, for transfer pricing purposes, the Swedish distributor could not control the main risks in the Puma Group and therefore should not have carried the local market risks. The adjustment, made… – Continue reading

Framework / G20 / Lease / Multinationals / OECD / Permanent establishment / Revenue / Transfer pricing

Countries launch review of country-by-country reporting framework for multinational groups

Published by: MNE Tax - February 9, 2020

An OECD-led group of 137 countries that work together on multinational group tax issues has released a consultation document and has requested public feedback to assist in a planned review of country-by-country reporting. The countries, known as the “Inclusive Framework on BEPS,” also scheduled a public consultation on the topic for March 17.
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