SINGAPORE LEGISLATION AND BEPS PROJECT Singapore has committed to the global implementation of the BEPS Project proposed by the OECD. Particularly, a lot of attention has been given to Actions 8-10, pertaining Transfer Pricing (TP). More precisely, the cornerstone for TP law in Singapore comprises the Income Tax Act. The Income Tax Rules of 2018 … Read more
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
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
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
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
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
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
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
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 of vertical integration in order to ensure economies of scale and higher efficiency. In more detail, a group can be structured from companies incorporated in … Read more
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 multinational enterprises (MNEs) to follow the same pricing policy for intra-group and uncontrolled transactions, under comparable circumstances. Otherwise, the controlled companies shall take the necessary … Read more
