In conjunction with revisions made to the OECD Guidelines, greater scrutiny has been placed on the economic substance of these transactions, the options realistically available to the counterparties, and the ability/capacity to bear risk within entities of a multinational enterprise.There has also been a significant shift in the way in which tax authorities have sought to analyse and challenge intercompany loan, guarantee, cash pooling and other financial transactions from a transfer pricing perspective. Cabinet Decision No 55 of 2023 was issued on on Determining Qualifying Income for the Qualifying Free Zone Person for the Purposes of Federal Decree-Law No. Economics Department - Research interests in macro economics, industrial. The highly anticipated Decisions on the Corporate Tax Rules for Free Zones have recently been released. Ph.D University of Virginia Aug 2003 - Aug 2008 5 years 1 month. These transactions are central to getting funding across the multinational group and service liquidity provision, long term funding, and other operational and tax needs. Transfer Pricing Manager PwC 2012 - 2016 4 years. Transfer Pricing Director PricewaterhouseCoopers Jul 2016 - Present7 years McLean - Advised multinational companies on transfer pricing compliance, planning, audit resolutions, competent. Our global breadth and country-level depth as a financial transactions transfer pricing (FTTP) network provides us with the tools and experience to deliver tailored, sustainable solutions in a dynamically changing global FTTP environment.įinancial transactions are often the most extensive and material transactions within multinational groups.
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