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25 May, 2020
As the COVID-19 pandemic continues to evolve, causing substantial shifts in financial markets and the macro economy, there will be direct implications for multinational enterprises (MNEs). As governments enact new...
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19 May, 2020
Commercial transactions between the different parts of the multinational groups may not be subject to the same market forces shaping relations between the two independent firms. The expression "transfer pricing" generally refers to...
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06 Mar, 2019
During the last weeks, we have been writing and reviewing significant amendments to corporate laws and tax laws in offshore jurisdictions to satisfy their commitments made pursuant to the OECD's Base Erosion and Profit Shifting (BEPS)...
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11 Sep, 2018
Mark Friedlich, Senior Director of Tax and Accounting, North America, Wolters Kluwer, and a member of the Senate Finance Committee Chief Counsel's Tax Advisory Committee on Tax Reform, will be giving a presentation at the upcoming AICPA & CIMA U.S. Tax Reform Conference...
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13 Mar, 2018
Several multinational companies have been in the spotlight recently for not paying their fair share of tax. In Europe, companies such as Amazon and Google have been investigated by the European Commission for exploiting...
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08 Feb, 2017
The Cyprus Minister of Finance issued a Decree on 30 December 2016, introducing a mandatory Country by Country (CBC) reporting requirement for multinational enterprise groups generating consolidated annual turnover exceeding...
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30 Sep, 2014
Base Erosion and Profit Shifting is a hot topic within the international tax community, spurred on by the G20 backed OECD initiative. The OECD has outlined a stringent time frame to implement recommendations. What are the other approaches that could be adopted?
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05 Jun, 2014
The current transfer pricing provisions contained in section 31 of the Income Tax Act, 58 of 1962 came into effect on 1 April 2012 and are applicable for years of assessment commencing on or after that date.
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07 May, 2013
Main features: A Lux FinCo is entitled to the extensive Luxerñbourg DTT network and EC directives; No withholding tax on interest in Luxembourg; Virtually no statutory audit; Advance tax rulings from the Luxembourg tax authorities are possible and is highly recommendable to avoid discussions about the taxable spread; Annual accounts and taxable profit can be reported in another currency than the euro (' functional currency ruling' ).
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18 Aug, 2011
Panama is quickly emerging as the key gateway into and out of South America. Panama is a nexus of trade for South America and is hence going to be and already is an ideal jurisdiction for international trading businesses in services and goods. It competes for this title with Miami.
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