TP in Financial Arrangement, the case of Chevron

Chevron Transfer Pricing (TP) case regarding an intragroup financial arrangement was heard over 21 court days in Australia. More than 20 witnesses and experts from financial and tax sectors participated in the investigations of the case. Snapshot of the group structure Chevron Inc, the ultimate parent of the Group with its headquarters in the US. … Read more

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. Definitions 1. This Circular applies to any company carrying out group financing transactions (hereinafter referred to as a group financing company) meaning any entity that … Read more