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 transaction takes place. The basis for determining proper compensation is, in most cases, the arm’s length principle. In a nutshell, the arm’s-length principle requires that … Read more

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 which will govern how European companies will be taxed. Fundamentally, CCCTB will provide a framework for the calculation of the taxable profits. However, this will … 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

Transfer Pricing Practices in Russia

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 avoidance through transfer pricing schemes. However, accountants, auditors and tax professionals are aware for the principles, while Russian tax administration is alerted indeed. Reference to … Read more