International Tax Archives - Page 9 of 12

The Primary Advantage of Negotiated Transfer Pricing

Dispute Resolution, International, International Tax, Tax Dispute Resolution, Transfer Pricing / Dr Daniel N Erasmus

Discover the primary advantage of a negotiated transfer priceTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More and its impact on multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More. Learn why consulting TRM is essential for effective management.

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Landmark Transfer Pricing Case: France vs. Willink SAS

International, International Tax, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

Review of the landmark transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More case of France vs. Willink SAS, highlighting the importance of functional analysisFunctional analysis is the cornerstone of transfer pricing and international tax compliance, ensuring that intercompany transactions adhere to the arm’s length principle. It evaluates the roles, contributions, and risk profiles of entities within a multinational enterprise (MNE) to determine how profits and costs should be allocated. This process ensures that related-party transactions reflect the pricing that independent enterprises would establish... More, robust documentation, and adherence to the arm’s length principle.

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India’s Evolving Tax Treaty Landscape

International, International Tax / Dr Daniel N Erasmus

Discover how India tax treatyA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More challenges impact foreign investors and how Dr. Daniel N Erasmus’s expert team can help navigate these complexities.

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Understanding the Arm’s Length Principle of Transfer Pricing: A Comprehensive Guide

International, International Tax, Transfer Pricing / Dr Daniel N Erasmus

Explore the arm’s length principle of transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More in-depth with our comprehensive guide tailored for tax professionals and multinational executives.

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Analysis of BlackRock HoldCo 5, LLC v HMRC: Transfer Pricing and Unallowable Purpose Test

Europe, International, International Tax, TP Case Summaries, Transfer Pricing, United Kingdom / Dr Daniel N Erasmus

Explore the key aspects and implications of the BlackRock HoldCo 5, LLC v HMRC case, focusing on transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More and the unallowable purpose test.

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UK vs. Kwik-Fit Transfer Pricing Case: Implications for Multinationals

International, International Tax, Transfer Pricing, United Kingdom / Dr Daniel N Erasmus

Detailed analysis of the UK vs. Kwik-Fit transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More case, its global implications, and the value of expert guidance in transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More matters.

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TRANSFER PRICING: INTEREST ON SHAREHOLDER LOANS AND RELATED MATTERS

Africa, International, International Tax, Transfer Pricing / Dr Daniel N Erasmus

In this short video, Renier van Rensburg highlights the complexities of transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More interest on shareholder loans and related matters.

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WEBINAR: International Tax Planning & Structure Execution

Africa, International, International Tax, South Africa / Dr Daniel N Erasmus

Don’t miss our International Tax PlanningTax planning is the process of organising and structuring one’s financial affairs in a manner that legally minimises tax liabilities while ensuring compliance with relevant tax laws. The primary objective of tax planning is to reduce the amount of taxes paid, optimise the use of available tax benefits, and preserve wealth. It can be applied at various levels, including personal... More & Structure Execution event designed to boost your collaboration skills.

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What is the most common Transfer Pricing Method? The Transactional Net Margin Method Explained

International, International Tax, Questions & Answers, Transfer Pricing / Dr Daniel N Erasmus

Uncover the essentials of the Transactional Net Margin MethodThe Transactional Net Margin Method (TNMM) is one of the five primary transfer pricing methods recognised under the OECD Transfer Pricing Guidelines. TNMM is applied to evaluate whether the conditions of a controlled transaction between associated enterprises are at arm’s length. Unlike traditional transaction methods, which directly compare prices or gross margins, TNMM compares the net profit margin relative to... More, the most common transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More strategy for global businesses.

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The Three Types of Transfer Pricing

International Tax, Transfer Pricing / Dr Daniel N Erasmus

Discover the essentials of transfer pricingTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More methods, key for compliance and optimal business strategy in global markets.

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