Does your foreign parent company documentation provide AU compliance?
Learning Centre • Videos & Webinars • Does your foreign parent company documentation provide AU compliance?
Learning Centre • Videos & Webinars • Does your foreign parent company documentation provide AU compliance?
A US multinational company with subsidiaries around the world, including Australia, recently prepared new US transfer pricing documentation.
The company applies their transfer pricing policies on a global basis. The US tax director instructs the Australian tax director to use this documentation to support the prices charged by the US Company to the Australian subsidiary.
Is the US documentation acceptable in Australia?
Global Minimum Tax (GMT) is one of the largest tax reformations as part of the initiative under Pillar 2 of the Base Erosion Profit-Shifting (BEPS) 2.0 project.
This article will provide an overview of what global minimum tax is, why it's important, and how it impacts multinational corporations and the global economy.
This article will explore the history of global minimum tax policies, from their origins to the latest developments, including the recent OECD/G20 agreement.
This article will discuss how technology can help multinational corporations streamline their global minimum tax compliance.
This article will discuss how global minimum tax policies affect multinational corporations, including changes to their tax planning strategies and compliance requirements.
This article will provide practical advice for multinational corporations on how to navigate the complexities of global minimum tax compliance.
This article will provide an overview of the legal and regulatory considerations that multinational corporations need to be aware of when dealing with global minimum tax.
This article will speculate on the future of international taxation in light of global minimum tax policies, including potential trends and challenges that may arise.
This article will examine the challenges and opportunities that global minimum tax policies present for developing countries, including their potential impact on tax revenue and economic development.
On 19 February 2024, OECD published the final report on Pillar One -Amount B, is designed to simplify and streamline the application of the arm’s length principle.
We are thrilled to share that Adriana Calderon, Director of Transfer Pricing Solutions Asia, has been appointed by ISCA as a Transfer Pricing Roundtable Representative for SCTP.
The indicative margin recommended by IRAS are market interest rate to be adopted by Singapore taxpayers for related party loans not
exceeding SGD15 million.
Generally, the IRAS publishes the indicative margins at the beginning of each calendar year.
If you are reading this article the chances are that you enjoy discussing about technical aspects of transfer pricing as much as we do. Any transfer pricing aficionado knows that changes to the OECD Transfer Pricing Guidelines are a reason for excitement in the tax and transfer pricing world.
The Malaysian Finance Bill 2020 incorporates transfer pricing-related changes to the current Income Tax Act, 1967 (“ITA”). The changes permit significantly greater authority to the Malaysia Inland Revenue Board (“MIRB”) and re-emphasises the importance of transfer pricing compliance, with effect from 1 January 2021.
Thec Covid-19 pandemic has triggered the most severe recession and is causing enormous damage to the world economy. The economic downturn will impact a group’s transfer prices, analysis and documentation, more so with the BEPS Action Plans in place and the high level of transfer pricing scrutiny across the globe.
JobKeeper forms part of taxable income in the tax return. Makes sense, it is a subsidy against wages, so I am sure there are no surprises there, but how do you assess the arm’s length financial outcomes of the entity for transfer pricing purposes?
The ATO expect that Australian entities will retain the benefit of the JobKeeper payment they receive. So how do you treat the JobKeeper payments for transfer pricing purposes?
Singapore introduced compulsory transfer pricing documentation effective from the year of assessment (YA) 2019. A new penalty regime was also included for non-compliance with the TP documentation requirements.
We are thrilled to announce that Transfer Pricing Solutions is shortlisted for the International Tax Review Asia Tax Awards 2020 with several nominations!
The Inland Revenue Authority of Singapore (IRAS) recognises the diversity in the commodity marketing/trading (CMT) activities undertaken by CMT entities in Singapore and the wide-ranging values they could bring to their multinational enterprise (MNE) group.
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