Ryan Finley explains why the IRS’s recent advice memorandum on periodic adjustments may signal a significant change in ...
The Delhi High Court has made it clear that a dispute with respect to arm's length price in a transfer pricing can be ...
While South Africans turn their focus to the upcoming budget speech in February 2025, many are wondering how the expected ...
Brazilian taxpayers and practitioners continue to clamor for more guidance on the country’s new transfer pricing regime ...
Budget 2025 proposes a block assessment mechanism for transfer pricing to reduce compliance burdens. The new approach allows ...
Transfer pricing refers to the actual price charged in transactions between related entities within the same multinational ...
The proposed international financial centre (IFC) is inspired by global models such as Singapore’s Marina Bay and Dubai’s ...
The first arm’s-length transfer pricing audits in the United Arab Emirates are coming this year, with unique challenges for ...
Rationalisation of transfer pricing provisions for carrying out multi-year Arm’s Length Price determination 92CA. (1) Where any person, being the assessee, has entered into an international ...
Transfer pricing rules are designed to ensure that income from international transactions or certain domestic transactions is determined on the basis of an “arm’s length price” (ALP). This means that ...
Additionally, the finance minister expanded the scope of safe harbour rules to reduce litigation and provide certainty in international taxation.
Budget 2025 proposes a block assessment mechanism for transfer pricing to reduce compliance burdens. The new approach allows predetermined Arm's Length Price to apply for two additional years ...