Brazil: Brazilian Revenue Service issues ruling on deductibility of cost-sharing expenses and applicability of transfer pricing rules.The article discusses the Brazilian Revenue Service's position on the tax deductibility of cost-sharing expenses and the applicability of transfer prizing rules. If proven...
The rules on transfer pricing (TP) are historically limited to international transactions only. Moreover, with effect from 1 April 2013, the scope of the transfer pricing has been expanded to different domestic transactions and is therefore active from the assessment year (A.Y) 2013-14. What d...
consideration of the possibility of offset or aggregation with other positions Unclear what happens to US transfer pricing position if you cannot reach more likely than not for FP Audit issues – Multiple Adjustment Theories Measurement Similar analysis for US Sub and FP—what is the amount of U....
More complex for FP FIN 48 states that “each tax position must be evaluated without consideration of the possibility of offset or aggregation with other positions Unclear what happens to US transfer pricing position if you cannot reach more likely than not for FP,15, 19、Audit issues Multiple ...
Regression analysis in transfer pricing analysis: applicability and acceptability.(Brief Article)Przysuski, MartinSwaneveld, HendrikPaul, PallaviOsoro, CharlesLalapet, Srini
The article focuses on Arbitration Convention Number 90/436/EEC of European Union, a medium for settling transfer-pricing controversies. It informs about mutual agreement procedure (MAP) in which enterprises are subjected to serious penalties. It presents several situations in which MAP is applicable ...
This paper presents some preliminary, qualitative results on the applicability of the implementation of a waste management and pricing system based on ''Pay As You Throw'' (PAYT) in Greece. PAYT is described and both its aims and potential benefits and problems are presented. Next, the waste ...
transfer pricingarm's length principletax treatiesinter-company financingShellIn this article, the authors examine the dynamics of inter-company equity financing transactions and conclude that the arm' s length principle should be applied to such transactions even if they do not result in immediate ...
The article focuses on the decision of the British Court of Appeal in the case Thin Cap Group Litigation v. Commissioners for Her Majesty's Revenue and Customers (HMRC), and the amendments to the transfer pricing legislation in Great Britain in 2011. According to HMRC, the country's thin ...
Before the retail electricity price package is executed, the electricity price is equal for each time period, and the user will not transfer the load because of the retail electricity price. Consequently, the user will choose the most comfortable mode, and usually set it as the reference value...