The Multistate Tax alert archive includes external tax alerts issued by Deloitte Tax LLP's Multistate Tax practice during the last four years. These external alerts highlight selected developments involving state tax legislative, judicial, and administrative matters. The alerts provide a brief summ...
The transfer pricing Q&A provides welcome clarification of intercompany loans in the TP context. 31 May 2024 Francisco Palacios + 1 New Q&A on transfer pricing issued by the Swiss Federal Tax Administration Additional transfer pricing guidance offers important insights into Swiss practice and the ...
Internal Revenue Service in May 2004 to apply the interest expense disallowance rules to loans between related affiliates. Background information on the disallowance rule; Scenarios which demonstrate how to apply the disallowance rule to intercompany borrowings; Advice for dealers in exempt obligations ...
Specifically, regarding financial transactions, the transfer pricing scope no longer confines itself solely to intercompany loans, but also extends to encompass guarantees (including insurance contracts), cash pooling, treasury operations, and other related activities. For all such transactions, the principl...
摘要: Many companies within a group have intercompany loans. The loans could be for funding the purchase of assets, to fund operating expenditure, for cash flow and capital needs, or for goods or services provided, and the consideration remains outstanding on the loan account....
This is a positive development for eligible taxpayers who may be interested in getting certainty on the Transfer Pricing treatment of their intercompany transactions in advance of undertaking the transactions. This APA can help to avoid costly and time-consuming disputes with the FIRS. ...
Transfer pricing, or the pricing of transactions between affiliates in different tax jurisdictions—also known as intercompany pricing—presents both tax opportunities and financial reporting risks for multinational businesses. Tax authorities place a heightened focus on transfer pricing to increase revenue, ...
statements is country-by-country disclosures of taxes and corporate activities from Form 8975, detail on foreign subsidiaries and their intercompany transactions from Form 5471, detail on capital gains and losses from Schedule D, and detail on firms’ depreciable assets from Form 4562. Because the ...
This means that taxpayers of all sizes, engaged in either domestic and/or cross-border intercompany transactions of any size, will be required to ensure that the prices are at arm’s length. Transfer Pricing documentation Under the Amendment Ordinance, companies are subject to...
backed securities or (2) an issuance of publicly offered or privately placed, rated or unrated securities, the payments on which are determined primarily by reference to one or more portfolios of residential mortgage loans consisting, in whole or in part, of some or all of the Mortgage Loans....