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2,698 results found

Article

TransFair Pricing Solutions S.A. | Belgium, Luxembourg | 9 Feb 2021

Court decision about exchange of information requests in a transfer pricing audit

On 16 December 2020, the Higher Administrative Court ("HAC") ruled in favour of the Luxembourg Tax Authorities ("LTA") in an appeal (N ° 45072)…
Article

Studio Legale e Tributario Biscozzi Nobili Piazza | Italy | 15 Jan 2021

Updated transfer pricing documentation requirements

A new provision establishes the requirements for the suitability of transfer pricing documentation. In order to align the domestic transfer pricing…
Article

Kudun & Partners Ltd | Thailand | 11 Jan 2021

Thailand’s Transfer Pricing Regulations Update: Adjustment of Income and Expenses, and Threshold for the TP Disclosure Form

Since the fiscal year of 2019, companies or juristic person belonging to the same group (the “Related Companies or Juristic Partnerships”) are obliged…
Article

Arendt & Medernach | OECD | 28 Dec 2020

OECD releases helpful new guidance on transfer pricing during the pandemic

It is clear that government restrictions and trading difficulties have created an environment in which existing transfer pricing policies will not…
Article

Clayton Utz | Australia, OECD | 16 Dec 2020

Hold period issues

The distribution of profit and capital will need careful consideration by offshore investors.
Article

Proskauer Rose LLP | European Union, OECD, United Kingdom | 15 Dec 2020

UK Tax Round Up

Draft regulations providing for employee and employer national insurance contribution (NIC) exemptions from payments made to employees to cover the…
Article

Gowling WLG | Canada | 27 Oct 2020

COVID-19 just made transfer pricing more difficult

The COVID-19 pandemic has made the lives of hundreds of millions of people around the world uncertain, wreaking havoc on all aspects of our daily…
Article

Brooks & Knights | Nigeria | 26 Oct 2020

First Transfer Pricing Judgment in Nigeria - Prime Plastichem v. Federal Inland Revenue Service

On 19 February 2020, the first judgement on transfer pricing in Nigeria was delivered by the Tax Appeal Tribunal (Tribunal) in the case of Prime…
Article

Loyens & Loeff | Luxembourg | 11 Sep 2020

Transfer pricing: taxation and digitalization of the economy

Peter Moons and Sophie Ogden contributed to the Luxembourg chapter of the comparative study of typical transfer pricing issues. This overview is…
Article

Loyens & Loeff | Belgium | 18 Aug 2020

State aid update: decisions opening individual investigations on Belgian excess profit rulings published

On 11 August 2020, the Commission published its decisions to investigate in depth the treatment of 39 Belgian companies that had obtained an ‘excess…
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