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Intra-group loans under the arm’s length principle
Against the backdrop of an increased regulatory focus on funding arrangements, Rachit Agarwal, Joel Cooper and Randall Fox consider some important transfer pricing points for practitioners.
Funding arrangements are an essential consideration..
Online Published Date:
04 September 2019
Appeared in issue:
Vol 24 No 03 - 04 September 2019
Translating tax returns
Tax planning arrangements for online companies with remote customer bases are under scrutiny from various international governments and regulators. Tim Walford-Fitzgerald presents some of the key points up for discussion.
Since the heyday of..
Online Published Date:
04 September 2019
Appeared in issue:
Vol 24 No 03 - 04 September 2019
A review of Canada’s foreign affiliate dumping provisions – prevention of multinational surplus stripping
Mark Woltersdorf and Larry Nevsky consider the detail of the provisions found in Section 212.3 of the Income Tax Act, including their purpose and some application examples.
Online Published Date:
04 September 2019
Appeared in issue:
July/August 2019 - 28 August 2019
A review of Canada’s foreign affiliate dumping provisions – prevention of multinational surplus stripping
Mark Woltersdorf and Larry Nevsky consider the detail of the provisions found in Section 212.3 of the Income Tax Act, including their purpose and some application examples.
Online Published Date:
04 September 2019
Appeared in issue:
Vol 24 No 03 - 04 September 2019
Legislation day: Finance Bill 2019/20 is on its way
Draft legislation has been published for consultation ahead of Budget 2019.
In accordance with the Government’s “Tax Policy Cycle” for tax changes, the draft clauses for Finance Bill 2019-20 were published on 11 July 2019. On..
Online Published Date:
04 September 2019
Appeared in issue:
Vol 24 No 03 - 04 September 2019
The month in accounting
The International Accounting Standards Board (IASB) recently published amendments to its financial instruments standards designed to provide relief to companies facing uncertainty from the phasing out of interest-rate benchmarks such as interbank..
Online Published Date:
26 September 2019
Appeared in issue:
Vol 24 No 07 - 03 September 2019
New rules on transfer pricing master and local files in Bulgaria
Bulgaria has recently introduced obligatory transfer pricing documentation to further develop its legislation in line with the OECD’s Transfer Pricing Guidelines and the BEPS Action 13 report, “Guidance on the Implementation of..
Online Published Date:
26 September 2019
Appeared in issue:
Vol 24 No 07 - 03 September 2019
Collaborating with the global tax reform agenda
As an active participant in EU and OECD initiatives, Ireland has had a busy few months in tax policy, as Catherine O’Meara and Olivia Long summarise below.
In terms of general action on corporate tax over the past five years, Ireland has..
Online Published Date:
26 September 2019
Appeared in issue:
Vol 24 No 07 - 03 September 2019
The devil is in the detail - lessons from Lamesa
The fear of US sanctions and their extraterritorial reach has long been appreciated by non-US lenders and borrowers. A recent case in the UK High Court has taken their impact to new levels, as Emma Radmore explains.
In Lamesa Investments Ltd v..
Online Published Date:
26 September 2019
Appeared in issue:
Vol 24 No 07 - 03 September 2019