Schoenherr Attorneys at Law
The General Court (GC) of the European Union ruled in favour of Apple in the state aid case regarding Apple's Irish tax structure, annulling the 2016 decision of the European Commission (EC).
Ernst & Young
Mandatory disclosure rules are not something new for European Member States ("EU MS").
Our Firm is the winner in the category of Transfer Pricing Advisory Firm of the Year in Cyprus – 2020.
For many businesses, their IPs is the main profit driver. This is more prominent in the digital era and economy in nowadays. The IP is amongst the main reasons why some businesses...
ATOZ Tax Advisers
On 15 July 2020, in the Apple case, the EU judges (General Court) concluded for the second time in less than one year that the EU Commission failed to demonstrate that by issuing a tax ruling dealing with transfer pricing matters, ...
While Finance Bill 2020 ("the Bill") includes measures to support the domestic economy during the COVID-19 crisis and in the context of Brexit, the Bill includes no fundamental changes to Ireland's...
Ireland's corporation tax regime has long been a core part of its economic policy mix and is a long-standing anchor in respect of its offering on foreign direct investment.
The High Court of England and Wales recently held that a claim under a tax covenant in a sale and purchase agreement was unenforceable because the claim notice did not contain sufficient detail...
Ireland is a leading European jurisdiction for the establishment of bond-issuing special purpose vehicles ("SPVs"), securitisation companies.
Luxembourg continues to be a global leader as a platform for
international business, investment funds, and cross-border
financing. At the outset of COVID-19
North Macedonia became the 117th member to join the Inclusive Framework ("IF") for the global implementation of the Base Erosion and Profit Shifting (BEPS) Project in August 2018.
On 6 August 2020, the Russian Federal Tax Service published Letter No. SHU-4-13/12599@ "On certain issues regarding taxation of intra-group services" (the "Letter") ...
Federal Law No. 265-FZ of 31 July 2020 (the "Law") limits the VAT exemption for granting use rights for certain IP assets and introduces a special tax regime for companies in the IT industry.
Baer & Karrer
In an international context, Switzerland is considered an attractive business location, not least due to the Swiss tax system.
Esin Attorney Partnership
25 Şubat 2020 tarih ve 31050 sayılı Resmî Gazete'de yayımlanarak yürürlüğe giren 2151 sayılı Cumhurbaşkanı Kararı ("Cumhurbaşkanı Kararı") ile Transfer Fiyatlandırması Yoluyla Örtülü...
Esin Attorney Partnership
The Presidential Decree No. 2151, published in the Official Gazette dated February 25, 2020 and No. 31050, and which entered into force on the same date ("Presidential Decree") amended the...
With 2151 numbered Decision on Hidden Income Distribution by Transfer Pricing, there have been amendments made in the General Communique Regarding Hidden Income...
"General Communiqué No 4 on Disguised Profit
Distribution by Way of Transfer Pricing" Has Been Published
Regarding the Postponement of the Deadline for the Notification
Filing and the Country-by-Country
8.11.2007 tarihinde Resmî Gazete'de yayımlanan 1 Seri No.lu Transfer Fiyatlandırması Yoluyla Örtülü Kazanç Dağıtımı Genel Tebliği ve 06.12.2007 tarih 2007/12888 sayılı Bakanlar Kurulu Kararı...
Within the scope of the "Review of Transfer Pricing Certification Obligations (Guide)" of the OECD's BEPS 13th Action Plan, it is aimed to determine related person transactions ...