In response to the Organisation for Economic Co-operation and Development (OECD) revisions to transfer pricing of financial transactions, the Japanese transfer pricing administrative guidelines have been reformed in Japan effective 1 April 2023. The latest revisions clarify the application of...

On 19th February, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting published its report on Amount B under Pillar 1, which intends to provide a simplified and streamlined approach to transfer pricing compliance for entities engaged in baseline...

On 9 February 2024, the Tribunal issued a ruling in the case KETAT 143 (KLR) between the appellant Beta Healthcare International Limited (Beta Kenya) and the respondent the Commissioner of Legal Services and Board Coordination (KRA). The matter in dispute...

In due course, the EU Court of Justice (ECJ) may shed some light on the VAT intricacies of transfer pricing (TP) adjustments. In Arcomet, the Bucharest Court of Appeals asked the ECJ whether the amounts included in yearly equalisation invoices...

For more information on the topic join our webinar on 17th of September. One of the most debated topics in the international tax arena is Pillar 2, the global minimum corporate tax. Alongside this, work on Pillar 1 continues at...

The financial services sector remains firmly in the spotlight of global tax authorities and prudential regulators. Whether it is HMRC in the UK or the Internal Revenue Service (IRS) in the US, understanding how money moves between regulated entities and...

National differences and approaches to transfer pricing are evident all over the world. In particular, tax jurisdictions in developed countries have now taken quite advanced steps in approaching complex transfer pricing situations from a technical debate perspective. Whereas in some...

Providing information on taxation in 22 Central and Eastern European (CEE) states, the latest Mazars CEE tax guide analyses long-term taxation trends and fundamental tax regime changes in each country, both now and in previous years.

The Diverted Profits Tax (DPT), or what the media have dubbed the Google tax, was introduced in 2015 to dissuade and counteract contrived arrangements used by large multinational groups that divert profits from the UK and erode the UK tax base.

Transfer Pricing Bill in Israel passes third reading in June 2022 and is approved. What are the implications for businesses in Israel? In June 2022, the new transfer pricing bill was approved. This is another step towards the Israel Tax...

Following Italy’s new transfer pricing (TP) requirements1 introduced on 23 November 2020, there has been much discussion as to whether the taxpayer may benefit from penalty protection that also covers additional withholding tax otherwise due when the Italian tax authorities...

Advance pricing agreements (“APAs”) could provide taxpayers and revenue authorities with some certainty during the unprecedented times that we are living in. The African APA landscape is however underdeveloped, but some recent developments in South Africa (“SA”) indicate that this...

On 26 November 2021, the Italian tax authorities (“ITA”) issued the final version of Circular Letter no.15/E (the “Circular”), providing clarification on the new transfer pricing requirements introduced by Measure no. 360494 (“New Measure”) on 23 November 2020. This article...