France: New Tax Laws Permit Sister Companies To Consolidate
France’s 2015 Finance Act and the Rectificative Finance Act for 2014 have entered into force. According to new law, the changes are below; New rules permitting sister companies to f for tax purposes. A reduction in the real estate
See MoreAustralia: Practice Statement PS LA 2014/2 released by the Australian Taxation Office
The Australian Taxation Office (ATO) released guidance on what the ATO expects taxpayers to prepare in order to comply with the transfer pricing laws and manage related risks on 17 December 2014. According to guidance 25% penalty applies and
See MoreNetherlands – Dutch taxpayer liable for Swiss captive subsidiary’s profits
A recent decision by a district Court in the Netherlands involved a Swiss captive insurance company that did not have any employees. The Court reached the decision that the tax authorities in the Netherlands were correct in levying tax on a related
See MoreUkraine: New transfer pricing law
A transfer pricing Bill to amend the legislation with regard to transfer pricing and introduce best practice was registered with parliament on 12 March 2013. The Tax and Customs Committee of parliament has confirmed that the Transfer Pricing Bill
See MoreCanada: CRA issues transfer pricing memoranda
The Canada Revenue Agency (CRA) has to follow the OECD Guidelines when performing transfer pricing audits. Two new transfer pricing memoranda (TPM-13 & TPM-14) have been issued. TPM-13 deals with referrals to the Transfer Pricing Review
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