Acquisition International - Leading Adviser 2021 29 36 Acquisition International - Issue 1 2022 Nov21453 Transfer Pricing Pioneers! From ’22 on, look up, down, and all around you: you will need substantial Transfer Pricing Safety more than ever! Call Transfer Pricing Services |TPS to find out more! ou already feel like there is a twenty too much pressure on your international tax position! You’d better call it the twenty-tw(o)ilight of global taxation! You really need to look up: yes, for that TOP-UP TAX, which tax administrations finally agree is coming. This is the implementation of OECD’s Pillar 2! (Naturally, there is also a Pillar 1!) You really need to look down: yes, it’s about that minimum imprint/ substance for tax purposes, which any tax administration, especially in EU, would want to test! Allegedly, this is the new directive which would hunt down the shell entities! You really need to look behind and in front of you: yes, it’s about your tax report which anyone with an internet connection, especially in the Y EU, will want to question. This is the new Directive on Public Countryby-Country Reporting. In short, you really need to look around you: it’s still about the arm’s length principle, “under which transactions between Constituent Entities must be recorded by reference to the conditions that would have been obtained between independent enterprises in comparable transactions and under comparable circumstances”. This is the new old approach to Transfer Pricing Safety! And whenever it’s about TRANSFER PRICING SAFETY … it has our name on it: TRANSFER PRICING SERVICES, TPS in short. We’ve been preparing for more than a decade, studying tons of legislation, assesing thousands of tax structures, preparing sound transfer pricing files and indestructible benchmarking studies. TPS started 12 years ago, assisting multinational groups in the aftermath of the Great Recession. We are committed to continue assisting you in the aftermath of the Global Tax Revolution! Wait-and- see was never a good strategy in our field of work! Get in touch with TPS today! Company: Transfer Pricing Services | TPS Contact: Adrian Luca Email: [email protected] We’ve been preparing for more than a decade, studying tons of legislation, assesing thousands of tax structures, preparing sound transfer pricing files and indestructible benchmarking studies. Leading Transfer Pricing and Taxation Protection Firm of the Year, Romania
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