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A general introduction to transfer pricing in Switzerland

This article provides a general overview of the law and practice surrounding transfer pricing in Switzerland, including broader taxation issues and the outlook for future developments.

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A general introduction to transfer pricing in Cyprus

This article provides a general overview of the law and practice surrounding transfer pricing in Cyprus, including broader taxation issues and the outlook for future developments.

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New Draft Interpretation Note on Intra-group Financial Transactions brings welcome clarity

SARS has released a new draft interpretation note that will help to clarify issues around intra-group loans, but several key issues still need to be addressed Debt is an important source of financing for investment. However, intra-group financial assistance can create opportunities for base erosion and profit shifting. Base erosion profit shifting (BEPS) refers to tax planning strategies used by multinational enterprises to "shift" profits from a higher-tax to a lower-tax jurisdiction, which results in loss for the tax base of the higher-tax jurisdiction.

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The 2022 OECD Transfer Pricing Guidelines: Mostly An Update - Tax

On January 20, 2022, the OECD released the latest version of its OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.

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