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pdf Matrix on Key Transfer Pricing Issues regarding Treasury Activities Popular

Matrix on Key Transfer Pricing Issues regarding Treasury Activities

The UN released an updated draft on financial transactions in April 2019, which in addition to the discussion draft released by OECD in 2018, provides guidance on the disputes in transfer pricing issues. Here we compare the two drafts and advanced domestic practices (i.e. the UK and Australia). When comparing different key variables to determine (i) an acceptable D/E level; (ii) an acceptable interest rate (includes guarantee fees), OECD draft, UN draft, UK legislation, Australian legislation require the following checks...

pdf Transfer Pricing Aspects Of Financial Transactions – Replacing LIBOR And High FX Risks And Impact Popular

The London Interbank Offered Rate (LIBOR) is the global benchmark for financial transactions with an estimated volume of USD 370 trillion. The discontinuation of LIBOR at the end of 2021 requires market participants to use alternative key interest rates from 1.1.2022 at the latest.

pdf How Technology is bringing a new paradigm for Tax and Transfer Pricing documentation and global controversy Popular

This article provides an overview of the important role brought by technology in Tax and Transfer Pricing in the post-BEPS ("Base Erosion and Profit Shifting project") world.

default OECD Proposals Undermine The Arm’s Length Principle Popular

OECD Proposals Undermine The Arm’s Length Principle

The Organisation for Economic Cooperation and Development (OECD) recently released a policy note (approved by the 127 members of its Inclusive Framework (IF)), hosted a webcast and held a public consultation meeting to consider possible solutions to the tax challenges arising from digitalization of the economy.

pdf How Technology Is Changing Taxation In Latin America Popular

How Technology Is Changing Taxation In Latin America

This article provides an overview of the important role played by technology in taxation and transfer pricing in Latin America, and presents comprehensive research to illustrate the digital path taken by tax administrations and corporations in Latin America and worldwide.

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