On May 11, the Dutch Ministry of Finance published a new Transfer Pricing Decree. But don’t think this is an isolated case, applicable only to Dutch MNCs (Multinational Companies). This is a coordinated approach by Tax Authorities globally. Hence relevant for MNC’s worldwide. This article takes a closer look. Continue reading Transfer Pricing re-calibrated: “Value creation”. The new Dutch TP Decree.
A closer look at why the Japanese economic landscape (aging and shrinking population, near flat GDP and retained earnings leads to an increased focus on global cash management. But also a look at if Japanese banks can still catch-up in order to meet demand? What serious challenges do newcomers to this area face. Especially a diversified client-base may prove to be an “Achilles’ heel”. Continue reading Japanese Economy Sets Stage For Global Cash Management. Who can service?
The outcome of the referendum is clear, the U.K. wants out. Fast. However, the whole process of the Brexit has not even started yet. Hard statements during public appearances set the scene. Is this negotiation rhetoric or something else? What are the consequences we could anticipate? What exit scenarios are available? How does the legal framework interfere? Continue reading Brexit? Yes! But keep in mind, until you’re out, you’re in!
The Cayman Islands may be beautiful, but the world’s wealthy, and some of the world’s biggest businesses are there for another reason, its financial system. This article sheds light on how this works, against the backdrop of tax avoidance, the moral aspects, and financial institutions’ Customer Due Diligence / Know Your Customer. Continue reading Who and What Determines Offshore Ethics? – A perspective on tax avoidance, KYC v2.0
If the price isn’t right, suspicion of Corporate Tax Avoidance could rise.
A discussion paper against the backdrop of OECD’s “Transfer Pricing Reporting”. The recent crises and some scandals shed light on the risk that a certain way of applying transfer pricing was jeopardizing the arm’s length principle itself. That’s why the OECD aims at redrafting the guidelines. Transfer pricing has become one of the main risks to be addressed and managed by MNCs. How does this potentially affect Treasury? What are best practices? Continue reading Transfer Pricing? Keep it at arm’s length! (BEPS Action #13)
Qualification mismatches can be powerful tools to reduce tax costs in a tax planning structure. How the OECD proposes to neutralize the effects of hybrid mismatch arrangements may/will impact MNC’s. This article provides a technical analysis. Continue reading Dealing with OECD’s “Neutralizing the effects of hybrid mismatch arrangements” (BEPS Action #2).
November 3rd this year, the IRAS (Inland Revenue Authority of Singapore) published an update of its guidelines as it pertains to related party transactions. Starting 2018, if the value of related party transactions in the audited accounts for the financial year exceeds a fairly low threshold of 15 million SGD, certain details of these related party transactions must be reported. Continue reading A Holistic view on Transfer Pricing – IRAS follows the Global Trend.