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 ...
Bologna set new asking price for Ndoye after Napoli approach in January
Dan Ndoye is a man in form and a man in demand following a brace in Bologna’s 3-2 win over Torino on Friday night and an ...
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 ...