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 …
Arm’s Length Principle
Introduction This Chapter provides a background discussion of the arm’s length principle, which is the international transfer pricing standard that OECD member countries have agreed should be used for tax …
Transfer Pricing Methods
The selection of a transfer pricing method always aims at finding the most appropriate method for a particular case. For this purpose, the selection process should take account of the …
Tax Department: Circular 3 for Back to Back Financial Arrangements
REPUBLIC OF CYPRUS MINISTRY OF FINANCE Ref. No.: 05.13.001 Interpretative Circular 3 — Income Tax June 30th, 2017 To all Assessing Staff Tax treatment of intra-group back-to-back financial arrangements 1. …