Panama: Transfer Pricing rules applying to a tax haven jurisdiction? It does happen.

Dealing with cases which have potential Transfer Pricing (TP) implications in Panama, requires a high level of expertise. Given that Panama is not an OECD member; an extended experience is necessary where the OECD practices are not applicable. The TP legal framework of Panama constitutes a hybrid since the OECD TP Guidelines are not directly … Read more

Peru: Sticking to the Transfer Pricing Guidelines as a means to become an OECD member.

Since Peru is aspiring to join the OECD until 2021, it has been trying to follow OECD directives on Transfer Pricing very closely. All this boils down to the conclusion that scrutiny for TP compliance in Peru is gaining ground continuously. Expertise in the realm is absolutely indispensable. Legal overview Peru has its own TP … Read more

Slovakia: The application of Transfer Pricing rules is ubiquitous

If compliance with Transfer Pricing (TP) rules is globally among the hottest themes in the realm of Tax Law, one thing is for sure: Transfer Pricing in Slovakia is even further. It could not be different, since the Slovak TP legislation applies the obligation to prepare the documentation not only to foreign related parties but … Read more

China: Peculiarities necessitate a Transfer Pricing treatment

China’s colossal economy as well as its predominant role within the global market, result in the emergence of an increasing interest towards China Transfer Pricing (TP) Law matters. Since China is not a member of the OECD, any TP endeavor goes far beyond the classic TP practices, though. More precisely, chinese legal framework comprises a … Read more

Liberia: Where transfer pricing is in full bloom

Liberia is a typical example amongst the developing African countries making noticeable effort to expand their tax base to the size it should appropriately be, therefore collecting more taxes and adapt in the fast-changing local and global business environment. To that end, Transfer Pricing Regulation (TPR) was introduced by the Liberia Revenue Authority (LRA) with … Read more

Transactional Net Margin Method (TNMM): A case study for a distribution company

TNMM Method - Distribution Company

Introduction The Transfer Pricing (TP) rules were introduced to regulate the transactions executed between related companies. The effective TP framework is of main interest in cases where the related parties are established in different states or jurisdictions. In such cases, the various corporate tax rates and regimes, in general, may motivate multinational groups for profit … Read more

Transfer Pricing in Russia: What you need to know

The rules on transfer pricing were introduced in Russia in 2000, were substantially amended in 2011 and came into force on January 1, 2012. The rules did not refer directly to the OECD Transfer Pricing Guidelines even though they mainly follow these principles. The previous guidelines on transfer pricing had been invoked since 1999, but … Read more

Transfer Pricing in Malta: A review on Maltese corporate taxation

Transfer Pricing in Malta

Sustainable development of EU’ economies requires taking into account several issues, which are related to the increased scale of international trade. Globalization has led to a substantial increase of cross-border transactions between related parties and has exceeded 50% of all global trade. The tax rates and accounting principles are different in various countries. Multinational companies … Read more

TRANSFER PRICING: The Intangible Assets Case

Intangible Assets

The transfer pricing of intangible properties has always been a significant issue for multinational enterprises (MNEs). The excellent idea devoted to this matter with the current drive of the OECD to counter tax base erosion is dim long over-due. Indeed, the case with transfer pricing is technically considered a neutral concept but erroneously taken as … Read more

CCCTB: The concept and the effects in Cyprus and Malta

CCCTB: The concept and the effects in Cyprus and Malta

When states attain membership of the European Union (EU), the governments are in charge of enacting and implementing their local direct taxation policy. The tax framework of the member-states shall not contravene or interfere the laid down policies and directives of the EU institutions; therefore, the sovereignty of member states is extremely safeguarded. Although the … Read more