On 26 November 2021, the Italian Tax Authorities issued a Circular Letter providing clarifications on the new instructions introduced in November 2020 regarding the content and validity of the elective…
BestBikes, a super-premium bicycle brand, has entities throughout Europe. The group develops a new bicycle, owned and promoted by the German principal entity of the group, BestBikes International GmbH (“BBINT”).…
When analyzing financial transactions between affiliated parties, it is essential to consider the economic context or the economic rationale for the existence of such intercompany dealing. There is, in most…
As companies accelerate their digital transformation, embed new ways of working, and identify new growth opportunities, they are relying on tax perspective to help them navigate the challenges that arise…
Transfer pricing is all about substance - the functional analysis As per the OECD Transfer Pricing Guidelines (see the 5th bullet under section “Controlled transactions” OECD Transfer Pricing Guidelines for…
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