Category: Transfer pricing
Israeli tax circular addresses intercompany recharges from stock-based compensation
In 2018, the Israeli Supreme Court ruled that stock-based compensation must be added to the cost base for transfer pricing purposes. ... - Continue reading
Poland APA statistics reveal alarming trends
Poland’s National Tax Office has published statistics for its advance pricing agreement (APA) program, updated for 31 December 2020. ... - Continue reading
This week in tax: EU VAT, Glencore and Making Tax Digital
As the UK moves ahead with Brexit, businesses across the EU are trying to overcome the difficulties of complying with EU tax law and the increasing likelihood of UK tax law breaking with those same standards. ... - Continue reading
Canada: COVID-19 Just Made Transfer Pricing More Difficult
The COVID-19 pandemic has made the lives of hundreds of millions of people around the world uncertain, wreaking havoc on all aspects of our daily lives. Governments and taxing authorities are grappling with not only how to keep the broader macroeconomy viable over the short run, but also how to bring the economy back to fiscal balance in the medium and longer term. In an article published by the Gowling WLG Transfer Pricing & Competent Authority Group entitled "CRA Audit Activity: The Calm before the Storm?", it was hypothesized that the Canada Revenue Agency ("CRA") would likely step up audit activity, after the COVID-19 episode is finally behind us, to reign in government deficits. ... - Continue reading
Ireland releases tax bill, announces plan to enact interest deduction limits from 2022
On 22 October, the Irish government published Finance Bill 2020, which contains legislation to enact tax measures. The tax bill includes several provisions affecting multinational enterprises with operations in Ireland. ... - Continue reading
Cyprus: European Mandatory Disclosure Regime (EU MDR) – A New Reality For Cypriot Intermediaries, Another Burden On Cypriot Taxpayers?
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
Turkey: Amendments In Transfer Pricing General Communiqué
A few transfer pricing laws in Turkey have been amended as per the concerned General Communiqué. Here they are. ... - Continue reading
Enhanced transfer pricing regime amidst the pandemic
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
