Sentences with phrase «transfer pricing rules»

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.

Where the parties to a transaction or series of transactions do not deal with each other on arm's length terms or prices, the tax consequences of that transaction may be adjusted by the Canada Revenue Agency (CRA) in accordance with special provisions of the Income Tax Act (Canada), specifically the transfer pricing rules found in section 247.

Canadian transfer pricing rules are very broad.

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.

Hamilton has written the chapter relating to the UK transfer pricing rules in Prix de Transfert and authored (in part) the tax chapter of the PLC tax manual on management buyouts.

The case is being closely watched due, in part, to the involvement of the company's corporate bodies in the United States, its Swiss affiliate and because «practitioners are hoping the courts will clarify the interplay between major elements of Canada's transfer pricing rules, as well as the appropriateness of the Canada Revenue Agency's aggressive approach to transfer pricing disputes.»

Accounting and legal changes include new transfer pricing rules, enacted in 2012, which have just come into force.

There was also a mention of making relevant price information available across jurisdictions to implement international transfer pricing rules.

The goal of the policy, of course, is to stop companies from using tax havens or transferring pricing rules to avoid paying taxes.

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.

• Revenue Law is a significant growth area for the firm in response to market developments and increasing litigation in this field • The firm has achieved notable success in a favourable transfer pricing ruling for Unilever and has advised on successful appeals in income tax and VAT matters

Not exact matches

[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.

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.

The 2014 deliverables included reports on the digital economy and harmful tax practices, as well as draft rules on treaty abuse and the transfer pricing of intangibles.

We have worked on international tax - planning strategies and transactions, international tax consequences of cross-border acquisitions and dispositions of businesses, dual consolidated losses, the maximum utilization of foreign tax credits, Subpart F taxation, transfer pricing, VAT, the PFIC rules, sourcing of income, and the FIRPTA rules.

The more I think about it the more I believe that this is a smoke screen used by a government agency to rally public discord away from their own bureaucracies which via their HST, land transfer taxes and mortgage insurance rules — all percentages calculated on the sale price of the home by the way — do more to inflate house prices without providing any evidentiary benefit to the homeowner.

Annual Disclosure Notice Brokerage and Investment Advisory Services Cash Management Awards Points Program Rules Consolidated Report Disclosure Electronic Funds Transfer Services and Cash Management Program Debit Card IRA Clients — Notice of Approval International Disclosures Margin Account Facts and Disclosures Options Level Descriptions for Accounts at Baird Private Investment Management (Commission - Based Pricing) Disclosure Routing of Equity Orders Safety of Client Assets Schedule of Fees and Services Charges

Once you transfer your Ultimate Rewards points to an outside loyalty program, you are subject to the rules, fees and price charts of that program.

Once you have converted your SPG points to miles, they must be redeemed within that program, which means you need to know the redemption rules and prices for every program that you intend to transfer miles to.

Under normal international taxation rules established to set fair transfer prices (3), the iron ore would normally be sold at an «arm's length price», which is usually linked to the current market price.

We'll address how government officials plan to implement the new law, how companies are adjusting their transfer pricing strategies, and how the reduced corporate tax rate could impact other countries and WTO rules.

Representing both foreign and domestic clients, its lawyers have extensive experience in helping taxpayers manage large and complex audits and disputes, including those involving transfer pricing and the application of the General Anti-Avoidance Rule.

Since the agreed transfer pricing methods were both inappropriate and lasted too long, the Irish tax rulings did not respect the arm's length principle, thus they did not reflect market conditions and consequently, since they also led to an inferior taxable base than would have otherwise been the case, they conferred an advantage to Apple.

Guernsey does not have specific anti-avoidance rules such as transfer pricing, thin capitalisation or controlled foreign company rules.

Reinforcing transfer pricing (TP) rules to align outcomes with functions, risks assumptions and value creation;

For instance, Brazil wants to be part of OECD, but doesn't accept the OECD rules for transfer pricing calculation.

These areas include: doing business abroad, including through low tax jurisdictions; the remittance of foreign earnings from foreign subsidiaries of Canadian corporations; planning for interaction with Canada's network of international tax treaties and international tax issues; transfer pricing; personal emigration from and immigration to Canada; customs planning, including customs valuations, tariff classification and rules of origin considerations.

The UK has various anti-avoidance measures to prevent excessive use of debt, such as transfer pricing regulations, the worldwide debt cap and corporate interest restriction rules.

Earlier this year the OECD published «Addressing Base Erosion and Profit Shifting,» which looked at the root causes of BEPS and six pressure areas including the residence - source tax balance (particularly in a digital economy), transfer pricing issues, the effectiveness of anti-avoidance rules, and the existence of preferential regimes.

Based on the new Dodd Frank rules effective January 10th, a sale is defined as a «Flip Transaction» is the new price is at least 10 % higher than the previous sales price and deed has transferred within the last 90 days, OR if the new price is at least 20 % higher and the deed has transferred within 91 - 180 days.