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TPS Newsletter – October 2022

TPS Transfer Pricing Specialists recognized as Tier 1 TP firm

TPS is very proud to announce that the firm has been recognized for the second year as a Tier 1 TP firm. This is the highest ranking in World TP 2023, the comprehensive guide to the world’s leading transfer pricing firms.

World TP, produced in association with International Tax Review, provides annually rankings and profiles of the most effective Transfer Pricing practitioners in the world, covering more than 84 jurisdictions located on every continent.

Because transfer pricing is a multi-faceted enterprise covering a wide range of disciplines, the rankings include law firms, consultancies and advisory groups to represent the full scope of experience and skill in the market. This year’s research involved more than 3.600 practitioners in almost 900 firms and feedback from more than 11.000 clients.

 

Transfer pricing developments around the world

  • Netherlands

The Northern District Court of the Netherlands, in the context of an international restructuring operation involving a Dutch entity and another resident in Switzerland, confirms the criterion established by the Dutch Tax Authorities and considers that there has not been a mere transfer of certain assets, but that there has been a transfer of a complete company.

The Dutch Tax Authorities adjusts the valuation of the related party transaction carried out by the taxpayer by applying the discounted cash flow method to determine the value of the business transferred, resulting in an adjustment to the corporate tax base of EUR 82.9 million.

  • Greece

On 13 September 2022, a new draft law was tabled and will be put to a vote in the Greek Parliament. According to this, in the event of an upward adjustment of a taxpayer’s corporate tax base following a tax audit, the counterparty will have the right to apply the adjustment in the opposite direction upon submission of a corrective statement which will have to be accompanied by the tax audit report.

  • Poland

Regarding the deduction of expenses and its relation to transfer pricing obligations, the Regional Administrative Court of Gorzow Wielkopolski ruled on 8 September 2022, concluding that only insufficient transfer pricing documentation cannot give rise to a refusal to deduct expenses, and that the information on the calculations submitted by the relevant taxpayer can be a starting point for analyzing the income of related entities and determining whether the arm’s length principle is respected.

  • United Kingdom

With regard to the Finance Bill 2022-23, drafts of the clauses and updates proposed by the Government have been published. In this regard, in relation to the corporate income tax, and specifically the transfer pricing rules, it is established that largest UK business will be required to keep and submit a master file, a local file and a summary audit trail when required.  These documentation requirements will apply for accounting periods beginning on or after 1 April 2023.

 

 

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