Taxes Archives - Page 11 of 17 - Academy of Tax Law

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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In-depth Analysis of Ireland’s First Transfer Pricing Case

Dispute Resolution, Europe, Ireland, TP Case Summaries, Transfer Pricing / Dr Daniel N Erasmus

Discover the critical insights from Ireland’s first 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, impacting multinationals and tax authorities worldwide. Learn about the landmark ruling today.

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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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Understanding Management Fees in Transfer Pricing: Key Aspects and Best Practices

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

Learn about management feesManagement fees refer to charges imposed by a parent company or central management entity within a multinational group for providing centralised services to its subsidiaries or associated enterprises. These services typically include administrative, strategic, technical, or operational support. Management fees are often structured to cover costs incurred by the parent company and are allocated to benefiting entities under transfer pricing... More 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, including key aspects, challenges, and best practices to ensure compliance with tax regulationsTax laws form the backbone of any nation’s revenue system, setting the rules that govern how individuals and corporations contribute financially to support government functions. These laws define the types of taxes, the applicable rates, and the regulations regarding payment and compliance. They also outline the rights and obligations of taxpayers, ensuring a balanced and fair approach to funding public... More.

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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 Planning & Structure Execution event designed to boost your collaboration skills.

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