Sentences with phrase «of transfer pricing»

Patrick Cauwenbergh is Partner in and the leader of the transfer pricing practice of Deloitte Belgium, and co-heads the European Business Model Optimisation initiative.

Transfer pricing Avoiding transfer pricing disputes, or achieving favorable resolutions when they do arise, requires a comprehensive understanding of the transfer pricing rules, including those of any treaty partners, as well as proficiency and experience in the forums in which such issues can be addressed.

I joined the firm's Transfer Pricing group in 2010, and I am in charge of advising clients on any type of Transfer Pricing matters...

He has worked on a wide range of transfer pricing documentation, company...

She has broad experience with more than 11 years in the field of transfer pricing direct...

He is Head of Transfer Pricing at PwC.

He has a wide experience of more than 15 years in the field of transfer pricing and international...

Mr. Andrus retired from PricewaterhouseCoopers in 2011 and was appointed head of the Transfer Pricing Unit within the Tax Treaty, Transfer Pricing and Financial Transactions Division of the OECD...

Even if every effort is made to secure sufficient comparable transactions or overall to secure sufficient comparables with regard to similar entities and their overall or sector / market specific profitability, the development of transfer pricing documentation is as much of an art as it is a science because no two companies or transactions are alike, and adjustments always need to be made for the sake of consistency.

If the application of transfer pricing provisions in the Act results in such an adjustment, a taxpayer may be subject to a transfer pricing penalty, in addition to any tax, interest and administrative penalties due.

Samuel Maruca participated in a panel at the annual Institute on Current Issues in International Taxation event, and is quoted in a Law360 article regarding the current state of transfer pricing rules.

Tax assistance and representation of companies with respect to transfer pricing, including identification of controlled transactions, benchmarking, drafting of transfer pricing documents and notices of controlled transactions, as well as client representation before tax authorities and courts;

Introduction As the General Reporter for the Subject 2 (The Future of Transfer Pricing) of the 2017 IFA Congress in Rio de Janeiro, I joined the plenary session on August 29 in a panel chaired by Luís Eduardo Schoueri and composed of Isabel Verlinden, Jefferson Vanderwolk, Mateus Calicchio Barbosa, Natalia Quiñones, Richard Vann, and Yariv...

Based in London, Ms. Steedman has 25 years of transfer pricing experience with expertise in setting global strategy and implementing pragmatic transfer pricing solutions for multinationals.

Whether you seek to develop and analyze transfer pricing structures, identify and evaluate comparable transactions, prepare tax valuations or develop strategies for the successful resolution of transfer pricing controversies, we can help.

In respect of the transfer pricing audits (TP audits) of Cameco's 2010, 2011 and 2012 taxation years, the Minister demanded in - person interviews of 25 personnel from Cameco and six of its wholly - owned subsidiaries.

Due to the nature of transfer pricing disputes, taxpayers often turn to the Competent Authority Process, found in the Mutual Agreement Procedure («MAP») article contained in some of Canada's tax treaties, to seek relief from double taxation after an adjustment.

The deal implied, among others, detecting, defining and analytically describing intangible property eligible for the Patent Box regime, as well as the conclusion of a complex transfer pricing ruling with the Italian Competent Authority, since the aforementioned «Patent Box Regime» requires the use of transfer pricing techniques to evaluate the share of the taxable income of the applicant attributable to the exploitation of intangible goods.

Alternatively City pay their whole wages but this is reclaimed from the holding co in a kind of transfer pricing agreement.

The summary of issues explores various considerations arising in developing an internationally accepted and applied «template» for country - by - country reporting as a part of transfer pricing documentation, and considers accounting requirements and other information as the base for the information which might be included in the template.

The goal of transfer pricing is to set international prices so that more profits are realized in those countries that have lower tax rates.

«As expected, increased Premier League broadcasting revenues have had a direct impact on player costs both in terms of transfer prices and player wage demands.

He was quoted as saying: «As expected, increased Premier League broadcasting revenues had had a direct impact on player costs both in terms of transfer prices and player wage demands,»

If so, Surfivor Surf Camp has the right to charge 100 % of the transfer price.

Not exact matches

You may still have time to gift or transfer ownership to children (or to a trust for the benefit of future children or other relatives) at a discount to the ultimate selling price of the company.

But the company will benefit from the fund's decision to use XRP, in part because it controls large reserves of the currency (which may get a price boost from Arrington's announcement) and because the move may burnish Ripple's reputation as a money transfer platform.

Benefit from resolution of tax matters During the first quarter of 2017, the Spanish Supreme Court decided, in the company's favor, an ongoing transfer pricing case with the Spanish tax authorities related to businesses Cadbury divested prior to the company's acquisition of Cadbury.

Following this model, realtors transfer data from the MLS system into password - protected websites of their own making, which they intend for use by consumers, who assume the tasks of determining appropriate listing prices and open houses from their realtors.

The companies deny any improper transfer pricing and say they are in Singapore to be closer to Asian clients, to local expertise and trade routes, as the region accounts for a growing share of their business.

Laws regulating MLM typically 1) require that MLM companies explicitly permit their agents to cancel their agreements and to agree to repurchase inventories at not less than 90 percent of the original transfer price; 2) prohibit inducements under which the agent is told that he or she will earn a specific amount of money; 3) prohibit the purchase of a minimum inventory; and 4) prohibit operations under which agents are only paid for recruiting others.

There is also criticism of what's known as transfer pricing, which companies use to value transactions among their subsidiaries in such a way to put the most profits in low - tax jurisdictions.

The plan is China's contribution to a global effort to stamp out the common practice of multinationals altering the price put on labor, services or intangible asset transfers within global operations to allow firms to divert profits to low - tax countries.

[Internal transfer pricing] is a gray area to utilize loopholes in tax rules between different countries, but now the governments [of those countries] are acting to close the hole,» the source said.

Negotiating terms of those transactions involves what's known as «transfer pricing.»

It might be right: the CRA got thrashed in the Supreme Court in 2012 on one of its biggest transfer pricing cases, a long - running dispute with GlaxoSmithKline.

Wilde defines transfer pricing this way: «You're trying to get a realistic measure of your overall operations and to price accordingly.

«Amazon has algorithms and crawlers that go out and find the lowest prices and create this giant sucking sound, and they've taken it offline and effectively created a transfer in value from taxpayers to Amazon,» said Scott Galloway, professor of marketing at New York University's Stern School of Business told CNBC on Thursday.

The court said it was unconvinced by the U.S. arguments regarding the alleged negative effects of the EU decision on its tax revenues, the bilateral tax deals with EU countries and its efforts to develop rules on transfer pricing in line with OECD rules.

They include forcing hospitals to post their prices online, and pushing them to transfer patients» discharge records to their doctors electronically, even if the doctors are not part of the same health system.

«If we substitute a tax on marijuana cigarettes equal to the difference between the local production cost and the street price people currently pay — that is, transfer the revenue from the current producers and marketers (many of whom work with organized crime) to the government, leaving all other marketing and transportation issues aside we would have revenue of (say) $ 7 per [unit].

0 % intro APR on purchases and balance transfers for the first 12 months, after that variable APR of 14.74 % — 20.74 % † Same page link to Pricing and Terms

«I never hear talk about measures that would encourage upward harmonization of labour or environmental standards... tax measures that would prevent corporations from engaging in transfer pricing or discourage shifting profits to tax havens.

The Company has maintained documentation (including any applicable transfer pricing studies) in connection with such related party transactions in accordance with Sections 482 and 6662 of the Code and the Treasury Regulations promulgated thereunder and any comparable provision of any Tax law.

The effect of transfer payments to the financial sector — as well as the $ 5.3 trillion increase in U.S. Treasury debt from taking Fannie Mae and Freddie Mac onto the public balance sheet — is to support asset prices (above all those of the banking system), not inflate commodity prices and wages.

Within program expenses, major transfers to persons were up $ 1.1 billion, primarily due to higher old age security payments, reflecting an increase in the number of recipients and higher inflation, as benefits are indexed to quarterly changes in the consumer price index, major transfers to other levels of government were up $ 0.6 billion, reflecting legislative increases; while direct program expenses declined by $ 0.2 billion, as lower «other transfer» payments more than offset increases in departmental / agency operating costs.

Corporate tax services encompass a variety of permissible services, including technical tax advice related to U.S. international tax matters; assistance with foreign income and withholding tax matters, assistance with sales tax, value added tax and equivalent tax related matters in local jurisdictions; preparation of reports to comply with local tax authority transfer pricing documentation requirements; and assistance with tax audits.

It flourishes between corporate and business units through misalignment of strategy and hence priorities; between business units and support functions where a disconnect over appropriate services can lead to bloated costs; and between business units themselves when they act as silos, leading to a fragmented view of customers or lengthy internal transfer pricing negotiations.

The Organisation for Economic Co-operation and Development (OECD) has released a discussion draft of revised guidance on transfer pricing documentation and country - by - country reporting.

ONESOURCE simplifies the complexity of today's compliance challenges around the world, from indirect tax to data and workflow management to transfer pricing.

If the shares acquired upon exercise are disposed of more than two years after the date of grant and one year after the date of transfer of the shares to the participant (statutory holding periods), any sale proceeds that exceed the total exercise price of these shares will be long - term capital gain.