When applying the UK’s transfer pricing rules to compare an intra-group loan to the hypothetical arm’s length transaction that an independent third-party lender would have agreed to, there is no scope to read in covenants...more
The German Federal Ministry of Finance has published a draft law for the implementation of the EU Anti-Tax Avoidance Directive (ATAD Implementation Act) on 10 December 2019. This draft includes inter alia a new section 1a...more
What is it about? OECD proposals to tax the digital economy which will significantly impact all large tech companies that are consumer oriented.
What will the impact be? Businesses will pay more tax. Impact on cash-flow,...more
12/2/2019
/ Base Erosion Tax ,
Corporate Taxes ,
Digital Marketplace ,
FinTech ,
International Tax Issues ,
Multinationals ,
OECD ,
Profits ,
Public Meetings ,
Tax Liability ,
Tax Planning
HMRC has announced today the introduction of a new Profits Diversion Compliance Facility, which is aimed at tackling the avoidance of tax by multinationals by diverting profits outside the UK without proper economic...more
On 13 July 2018, Hong Kong enacted detailed transfer pricing legislation through the gazettal of the Inland Revenue (Amendment) (No. 6) Ordinance 2018 ("the Amendment Ordinance")....more