Mondaq Offshore: Tax > Transfer Pricing
Kinanis LLC
The Cyprus House of Representatives has recently voted a new law transposing the provisions of the European Union Anti-Tax Avoidance Directive (the "ATAD" or "Directive") into the local legislation.
Soteris Pittas & Co LLC
In Cyprus Transfer Pricing rules are regulated by the circular issued on 30 June 2017 by the Cyprus Tax Authorities (CTA) (the "Circular") revising the transfer pricing framework for companies ...
C.D. Messios LLC
This means that any rulings issued previously on IGFTs are, unless challenged in Court, to be considered as no longer binding.
Elias Neocleous & Co LLC
Interest costs disallowed by reason of the rules may be carried forward for up to five years.
Elias Neocleous & Co LLC
The report acknowledges the exit taxation rules adopted by the EU in the ATAD I and the implementation of the BEPS action plan.
GuernseyFinance
When I arrived in Guernsey from London in 1995, it was as part of the upskilling of the insurance industry here in response to changing sensitivities of the UK taxman.
ATOZ Tax Advisers
Since June 2013, the EU Commission has been investigating the tax ruling practices of several EU Member States with a view to detect potential State aid concerns.
Antoniou McCollum & Co. LLC
Cyprus is a member of the European Union and the Eurozone. A common law jurisdiction, Cyprus provides an established, stable and solid legislative framework.
Duff and Phelps
Consistent with the OECD framework, the IRD will also be participating in automatic exchange mechanisms designed to facilitate the exchange of CbCRs between countries.
Mayer Brown
The past few months have witnessed a number of important tax changes, which are included in this edition of the Bulletin.
TMF Group
A milestone in Hong Kong tax laws, the Inland Revenue (Amendment) (No 6) Ordinance 2018 introduces a formal transfer pricing regime.
ATOZ Tax Advisers
Over the last few years, transfer pricing and related documentation has become the hot topic in Luxembourg taxation in an evolving environment that is relying increasingly less on tax rulings
KPMG Luxembourg
The asset management industry in the United Kingdom is the one of the biggest in the world, while Luxembourg is often cited as a key jurisdiction ...
ATOZ Tax Advisers
The Luxembourg VAT Authorities released Circular n°790 in which they have provided some clarifications on the taxable basis to be considered in transactions involving related parties.
ATOZ Tax Advisers
The law of 21 December 2018 implements the EU Anti-Tax Avoidance Directive ("ATAD"), the aim of ATAD being to implement the BEPS (Base Erosion and Profit Shifting) ...
ELVINGER HOSS PRUSSEN, société anonyme
On 19 January 2019, the Luxembourg VAT authorities published Circular 790 ("Circular") to clarify Article 28 paragraph 3 of the Law of 12 February 1979 ...
KPMG Luxembourg
In a recent court case about transfer pricing for interest rates on intra-group loans, the court ruled in favor of the Luxembourg Tax Authorities (LTA).
Dentons
Article 80 of the EU VAT directive provides that member states have the discretion to take measures to combat VAT fraud or evasion.
Morgan & Morgan
The regulation of Transfer Pricing is one of the mechanisms through which the Directorate General of Revenue (DGI) seeks to avoid the erosion of the tax base.
Mayer Brown
The winter months have seen a range of significant measures in tax legislation, from tax incentives for foreign investment and various measures to promote the technology sector to building on earlier measures to increase tax collections.
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Kinanis LLC
The Cyprus House of Representatives has recently voted a new law transposing the provisions of the European Union Anti-Tax Avoidance Directive (the "ATAD" or "Directive") into the local legislation.
Elias Neocleous & Co LLC
The report acknowledges the exit taxation rules adopted by the EU in the ATAD I and the implementation of the BEPS action plan.
Duff and Phelps
Consistent with the OECD framework, the IRD will also be participating in automatic exchange mechanisms designed to facilitate the exchange of CbCRs between countries.
Morgan & Morgan
With the enactment of Law 57 of October 24th, 2018 that modifies Law 41 of 2007, creating a Special Regime for the Establishment and Operation of Multinational Headquarters and the Commission of Multinational Headquarters, ...
TMF Group
A milestone in Hong Kong tax laws, the Inland Revenue (Amendment) (No 6) Ordinance 2018 introduces a formal transfer pricing regime.
ATOZ Tax Advisers
Structures involving double non-taxation are being restricted. The EU will extend restrictions applying in case of mismatch situations from pure EU-to-EU hybrids to EU-to-non-EU hybrids.
ATOZ Tax Advisers
On 27 December 2016, the Luxembourg tax authorities released a new circular (the Circular) on the tax treatment of intra-group financing activities.
ATOZ Tax Advisers
Over the last few years, transfer pricing and related documentation has become the hot topic in Luxembourg taxation in an evolving environment that is relying increasingly less on tax rulings
KPMG Luxembourg
The asset management industry in the United Kingdom is the one of the biggest in the world, while Luxembourg is often cited as a key jurisdiction ...
Elias Neocleous & Co LLC
Interest costs disallowed by reason of the rules may be carried forward for up to five years.
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