IRS Memo Marks A Major Shift In Transfer Pricing Approach
Ryan Finley explains why the IRS’s recent advice memorandum on periodic adjustments may signal a significant change in ...
Changes sought in transfer pricing assessment
Budget 2025 proposes a block assessment mechanism for transfer pricing to reduce compliance burdens. The new approach allows ...
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An overview of intangibles in transfer pricing
In today’s globalised economy, intangible assets play a critical role in driving business value, particularly for ...
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Finance Bill 2025: Amendment related to Transfer Pricing
Transfer pricing rules are designed to ensure that income from international transactions or certain domestic transactions is determined on the basis of an “arm’s length price” (ALP). This means that ...
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Italy: Application of the transfer pricing regulations to interest-free intragroup loans
Federico Vincenti and Carola Valente of Valente Associati GEB Partners/Crowe Valente explain how an Italian Supreme Court ruling clarifies the evidentiary burdens and arm’s-length compliance ...
FM announces rationalisation of transfer pricing provisions to 3 years, will benefit GCCs, IT firms
Additionally, the finance minister expanded the scope of safe harbour rules to reduce litigation and provide certainty in international taxation.
GCC measures, framework to ease expansion for foreign companies
The budget measure essentially will allow GCCs to arrive at a transfer pricing rate in the first year through an internal ...
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Liverpool turn down transfer approach with two deadline day deals close
Tyler Morton could leave Liverpool before tonight's transfer deadline with Middlesbrough ... Middlesbrough have had an initial approach rebuffed with Liverpool valuing the 22-year-old well in ...
A nudge for foreign costo step up GCC play
Streamlining international taxation and expanding safe harbour rules for Global Capability Centres (GCCs) in India are ...