US Transfer Pricing Series: Understanding Competent Authority and MAP Processes in Treaties
The Competent Authority and Mutual Agreement Procedure (MAP) processes are important mechanisms that provide relief to taxpayers in cases of double taxation. In the United States, these processes are governed by treaties and regulations that outline the procedures for requesting assistance and relief. Under US tax treaties, taxpayers can request the competent authority to enter […]
Exploring Advance Pricing Agreements under US Transfer Pricing Regime
Transfer pricing, which refers to the pricing of goods and services between related parties across international borders, has been a subject of intense scrutiny by tax authorities around the world in recent years. The United States is no exception, and has established a comprehensive system for the enforcement of transfer pricing rules. One key component […]
UAE Ministry of Finance Issues Decision on Small Business Relief for Corporate Tax Purposes
In a move aimed at supporting small and micro businesses in the UAE, the Ministry of Finance has issued Ministerial Decision No. 73 of 2023 on Small Business Relief for the purposes of Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (the “Corporate Tax Law”). The decision is issued in […]
Maintaining Master File and Local File: Understanding the Conditions for UAE Taxable Persons
The United Arab Emirates (UAE) Corporate Tax Law mandates taxable persons meeting specific criteria to maintain both a master file and a local file in their relevant tax period. These files contain information on related party transactions and serve to provide the tax authority with sufficient data to assess whether the taxpayer has complied with […]
Exploring the Different Types of Advance Pricing Agreements Available in the US
Advance Pricing Agreements (APAs) are an important tool for multinational enterprises (MNEs) to mitigate transfer pricing risks and avoid disputes with tax authorities. The United States Internal Revenue Service (IRS) offers taxpayers the opportunity to apply for different types of APAs to achieve certainty and clarity on the transfer pricing treatment of intercompany transactions. In […]
Understanding the Validity of Advance Pricing Agreements in the US
Advance Pricing Agreements (APAs) are a useful tool for multinational companies to manage transfer pricing risks and provide tax certainty. An APA is an agreement between a taxpayer and a tax authority, which sets out the method for determining the transfer pricing of cross-border transactions. APAs provide taxpayers with the opportunity to resolve transfer pricing […]
Understanding Advance Pricing Agreements: Filing Fees
Transfer pricing is a complex area that has been subject to increasing scrutiny by tax authorities around the world. Companies engaging in cross-border transactions are required to adhere to the arm’s length principle to ensure that prices for goods or services are consistent with market values. One way to ensure compliance with transfer pricing rules […]