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The trial judge erred in relying on Singleton and Shell Canada for requiring a transaction-by-transaction approach, but s. 69(2) only requires that the price established in a non-arm’s length transfer pricing transaction is to be redetermined as if it were between parties dealing at arm’s length. If the circumstances require, transactions ...
Loyens & Loeff N.V. (L&L) is an international law and tax firm headquartered in Rotterdam. [1] It has offices in the Netherlands, Belgium, Luxembourg and Switzerland (home markets), as well as representation offices in major international financial centres. [2] It is ranked as the second firm in the European 100 ranking by The Lawyer. [3]
Whereas appropriate transfer pricing of tangible goods can be established by comparison with prices charged for similar goods to unrelated parties, transfer pricing of intangible goods, products of intellectual efforts, rarely has comparable equivalents. Transfer prices then have to be established based on expectations of future income. [16]
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Transfer pricing adjustments have been a feature of many tax systems since the 1930s. The United States led the development of detailed, comprehensive transfer pricing guidelines with a White Paper in 1988 and proposals in 1990–1992, which ultimately became regulations in 1994. [33]
People looking to save money for a big trip or financial investment may want to make plans around an "extra" paycheck in their pocket.. Employees who get paid on a biweekly basis (every other week ...
Qualified Lawyers Transfer Scheme (QLTS) is a series of two examinations for the license to practice as a solicitor in England and Wales designed for foreign-licensed lawyers. The QLTS supplanted the Qualified Lawyers Transfer Test (QLTT) on 1 September 2010. The QLTS assessment was designed to increase the number of recognised foreign ...
Every month, thousands of Eritreans attempt to flee repression, torture and indefinite forced conscriptions by embarking on a dangerous journey to Europe.