Beginner's Guide on Transfer Pricing
PublicationBeginner's Guide on Transfer Pricing
Transfer pricing consideration on cash pooling arrangement
Let's Talk TPAccording to the Organisation for Economic Cooperation and Development (OECD), the use of a cash pool is popular among multinational enterprises as a way of achieving more efficient cash management by bringing together, either physically or notionally, the balances of a number of separate bank accounts.
How BEPS Pillar 2 impacts taxation of Philippine entities of MNEs
Let's Talk TPTechnology is making the world smaller. More countries are linked and interconnected in trade relations, particularly in digital trade, which the Organisation for Economic Co-operation and Development (OECD) Global Trade Forum highlighted would continue to grow, representing around 25% of the total trade as of 2020. Likewise, the World Trade Statistical Review reported that digitally delivered services traded within Asia reached 43.2% of the continent’s total trade in 2021.
Transfer pricing considerations for intercompany loans
Let's Talk TPAs each delicate strand of Christmas light is unchanged from the walls, each Christmas ornament is undecked from the halls, and each Christmas tree is carefully dismantled and boxed up, we officially bid a fond farewell to the 2023 holiday season.
The real deal: Delineating transactions in transfer pricing
Let's Talk TPOne of the first lessons taught in accounting is the concept of ‘substance over form,’ which posits that transactions recorded and presented in financial statements must reflect the economic and factual substance over their legal form. It may be said that substance over form precedes double entry bookkeeping; it is the nexus of all financial transactions and serves as a guide for financial reporters in understanding, recording, and reporting thereof. Even in tax cases, equity and law always exalt substance over form. It is the nature of transactions that determines the taxability of transactions.
Transfer pricing and business restructuring
Let's Talk TPBloomberg reports that business restructuring, specifically global mergers and acquisitions (M&A) activity, reached $5.9 trillion in 2021, crushing the previous all-time high of $4.2 trillion set in 2015. In its article, Grant Thornton (GT) LLP said global M&A activity slowed in 2022 at a total value of $3.7 trillion, and most analysts are predicting that we could see a return to pre-2021 activity.
