Special Report on
Thin capitalisation and transfer pricing
Thin capitalisation and transfer pricing - Trends
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16 December 2009 marked the start of thin capitalisation rules in Brazil (Provisional Measure n. 472/09). The thin capitalisation rule is the first step towards future requirements of minimum proportions between debt and equity. Limitations apply on deduction of interest between Brazilian and foreign related legal entities. The new rule will increase the taxable bases of Income Tax (IRPJ) and Social Contribution on Profit (CSLL). Taxand Brazil investigates the key features of the new rules and how they impact multinationals. The limitation for deduction of interest applies to loans obtained from: 1) related parties that are ...
The question as to whether or not a group is securing effective tax relief for its financing costs is not a new issue. In fact, treasurers and finance professionals spend many hours locked up with their tax advisers with the precise aim of ensuring that effective tax relief is secured. Furthermore, in an increasingly complex tax environment, the raft of thin capitalisation, transfer pricing and anti-avoidance often makes this a difficult and arduous process, but again this is nothing new. With the first scenario there isn't too much to say in the context of this article. If a ... Read More
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