Introduction 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 …
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 …
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 …
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 …
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 …
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. …
Although Russia is a Non-OECD economy there are certain provisions for the implementation of transfer pricing policies in related party transactions. The regulatory framework is not keen on preventing tax …
