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 …
Transfer Pricing in Malta: A review on Maltese corporate taxation
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 …
TRANSFER PRICING: The Intangible Assets Case
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 …
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 …
Transfer Pricing compliance for distribution companies
The implementation of integrated business models and the development of national and multinational groups has been a trend for over 30 years. Many MNEs (Multinational Enterprises) reach a high level …
Comparable Uncontrolled Price (CUP method) in Real World
The arm’s length principle treats the members of a multinational group as operating in separate entities, rather than as inseparable parts of a single unified business. Therefore, it is required …
Documenting intragroup transactions on machinery and equipment
Transfer Pricing (TP) guidelines generally require associated entities to invoice each other appropriately so as to correspond to the value of the goods transferred or services provided whenever an intra-group …
CCCTB framework shifting Transfer Pricing and BEPS
On the 6th of November 2017 the European Commission will discuss the implementation of Common Consolidated Corporate Tax Base (CCCTB) in an effort to create a standard set of rules …
A complete Guide for Junior Analysts
1. Introduction A trаnѕfеr price is thе price at which goods оr ѕеrviсеѕ аrе trаnѕfеrrеd form one рrосеѕѕ or dераrtmеnt to аnоthеr or fоrm one mеmbеr оf a grоuр to …
Transfer pricing in Management Fee
Transfer pricing methodology in Management Fee agreements could turn to be very problematic for related party transactions. The main reason is that the agreements are not usually based on specific …