To ensure that taxpayers give appropriate consideration to transfer pricing requirements in establishing prices and other conditions related party transactions, and in reporting the income derived from such transactions in their tax returns and also enable tax administrations to have access to the information necessary to conduct an informed transfer pricing risk assessment, taxpayers are required to maintain contemporaneous transfer pricing documentation. A local file is one of those. We provide a succinct overview of a local file and its content. #WTSBlackwoodstone #WTSGlobal #TransferPricing #Tax #LocalFile #TPDocumentation
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As a firm, this month, one of our top projects was to evaluate a global transaction at a #multinational with multiple tax leakages identified by us and address such tax leakages with appropriate positions and technical interpretations. What does this mean to the management of the company? This means higher cash at disposal for operational activities and paying the proper taxes obligations. #tax #transferpricing
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The Finance Bill 2024 now grants the Federal Board of Revenue (FBR) Commissioner the authority to demand wealth statements and details of foreign assets from anyone. Amendments also broaden the scope to include individuals or entities ceasing business operations. These new tax laws aim to enhance tax compliance and accountability. Section 126A, introduced by the Tax Laws (Amendment) Act 2024, clarifies valuation for tax matters and extends the transfer date for pending cases from June 16 to September 16, 2024, due to a high case volume. This comes a week after the tax machinery decided to form two Anomaly Committees to address errors and anomalies in the Finance Bill 2024. #FinanceBill2024 #FBR #WealthStatements #TaxCompliance #TaxLaw #TaxAmendments #ForeignAssets #BusinessRegulation #Section126A #TaxAccountability #CxOnews #CxOGlobalForum
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Tax authorities closely scrutinize transfer pricing policies to prevent profit shifting and tax evasion. Proper documentation and compliance are essential. #TransferPricing #TaxAuthorities #Compliance
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In this Bloomberg Tax article, I discuss #IRS efforts to enforce more #TransferPricing penalties and its impact on taxpayers. Feel free to reach out if you’d like to continue the conversation or learn how Crowe can help your organization understand its transfer pricing obligations.
“There's often no single correct answer in #TransferPricing, and this can lead to extended disputes between taxpayers and the #IRS,” said Crowe #tax principal Sowmya Varadharajan to Bloomberg Tax, discussing the push to enforce transfer pricing penalties. https://bit.ly/4ewtzmE
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#Transferpricing remains a big part of income tax planning for #Fintech businesses. This is a good read... Bloomberg Tax article, my Crowe colleague Sowmya Varadharajan discusses an #IRS push to assess more transfer pricing penalties and its impact on taxpayers.
Lawyers Fear IRS Overreach With Transfer Pricing Penalty Focus
news.bloombergtax.com
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A growing push at the IRS to assess more transfer pricing penalties has sparked concerns among taxpayers that the agency is able to penalize any position it disagrees with—and even solid supporting documentation isn’t enough to eliminate the risk. The agency made the shift in recent years following internal criticism that it let companies off the hook for penalties if they provided even low quality documentation to prove their transfer pricing positions. But now, tax lawyers say the change means the IRS could assess penalties whenever it disagrees with the transfer pricing method the taxpayer chooses in its analysis, even if that choice is supported by thorough documentation and robust data. Read more below: #transferpricing #internationaltax #corporatetax #irs
Lawyers Fear IRS Overreach With Transfer Pricing Penalty Focus
news.bloombergtax.com
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Think You’ve Mastered Withholding Tax Procedures? Think Again. 🚫 The European Commission’s latest report reveals how fragmented withholding tax (WHT) procedures are costing businesses billions and hindering cross-border investments. Yet, many continue to bear these compliance burdens without seeking smarter solutions. Surprising, right? 🤔 At WTax, we complement the services of over 150 custodian banks to ensure investment funds and tax-exempt entities avoid unnecessary taxes. By expertly leveraging international tax treaties and reclaim mechanisms, we streamline the complex WHT landscape and enhance our clients' returns. Sure you’ve got it all sorted out? Maybe it’s time to rethink. 💡 Let’s connect and discuss how we can turn these challenges into opportunities for you. 🚀 #WithholdingTax #TaxEfficiency #CrossBorderInvestment #WTax #CustodianBanks #InvestmentReturns #Finance
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Taxpayers should always ensure that their related-party transactions are conducted at arm’s-length. In this issue of our #CCStaxtips, we look at: i) The types of adjustments relating to transfer pricing; ii) IRAS’ position on the adjustments made by taxpayers and other tax authorities; and iii) Under what circumstances should taxpayers make adjustments. Follow our page for more #CCStaxtips! #CCSTaxTips #TransferPricing
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The Finance Bill 2024 has allowed the Commissioner of the Federal Board of Revenue (FBR) to demand wealth statements and details of foreign assets from anyone. Amendments in the bill also propose broadening the scope to include individuals or entities ceasing business operations, reported Business Reporter. The new tax laws will help ensure tax compliance and accountability. Additionally, Section 126A, introduced by the Tax Laws (Amendment) Act 2024, now clarifies the valuation for tax matters and extends the transfer date for pending cases from June 16 to September 16, 2024, due to the high volume of cases. It bears mentioning that these regulations have surfaced almost a week after the tax machinery decided to form two Anomaly Committees to rectify its errors in the Finance Bill 2024 and remove anomalies in the proposed tax laws for 2024-25. Visit https://lnkd.in/dYepVRg8 to know more about us #FinanceBill2024 #TaxCompliance #Accountability #FBR #WealthStatements #ForeignAssets #Section126A #TaxReform #AnomalyCommittees
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Out now! We delve into the intricacies of transfere pricing in our June tax newsletter where we do an analysis of a very comprehensive case laws that touches on majority of issues in this area particularly for reasons of custom valuation. Access it here. https://lnkd.in/dadEmmPw
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