Transfer Pricing
Portugal Ups Documentation Requirements, but Extends Deadline to Complete It
Last year, Portugal stepped up its transfer pricing requirements, aligning with the OECD’s transfer pricing guidelines.
Last year, Portugal stepped up its transfer pricing requirements, aligning with the OECD’s transfer pricing guidelines.
It used to be that a market study would suffice when it came to transfer pricing documentation in Israel. But not anymore.
Transfer pricing legislation is spreading all over the Middle East and leading the way, of course, is Saudi Arabia. The country wants to diversify its revenue base and recognizes that transfer pricing could play a key role in that.
If you’ve been following negotiations surrounding the OECD’s global tax deal, then you know that the implementation of Pillar One has been pushed back to signing ceremony in mid-2023 with a possible roll-out in 2024.
For a country that so openly condemns tax evasion and avoidance, the U.K. would seem like an obvious candidate to adopt BEPS Action 13’s three-tier transfer pricing documentation requirements: the master file, the local file, and the country-by-country report.
Royalty payments are almost always scrutinized by tax authorities, as they’re viewed as an easy way to shift profits outside of a rightful jurisdiction to a low-tax country.
Looks like the global minimum tax is having a cross-border effect even before it’s actually implemented. Last week, the U.S. treasury announced that it would be ending a 43-year double tax treaty with Hungary.
It’s no secret that more and more countries are formalizing transfer pricing legislation and, in many cases, taking nods from the OECD’s transfer pricing guidelines.
If there’s one transfer pricing outlier in the world, it’s undoubtedly Brazil. The country’s transfer pricing model isn’t based on the arm’s length principle—instead, it adheres to fixed margins as opposed to comparability analyses.
On July 1, the Czech Republic replaced France in the rotating presidency of the EU Commission—and it will hold court for the next six months.