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  • By David Forst, Fenwick & West, Mountain View
  • By Rahul Mitra and Arun Saripalli, PricewaterhouseCoopers, India
  • By Wendy Chiu and Dave Barberi, PricewaterhouseCoopers, Taipei
  • By Katharina Padrutt, TAX EXPERT International, Zurich
  • Sophie Stylianou Simeon Grigorov Bulgaria's transfer pricing regulations are in line with the arm's-length principle, under Ordinance H-9 of August 14 2006 of the minister of finance on Procedure and Ways of Application of the Methods for Determining Market Prices (effective from September 2 2006), though they needed further clarification, as far as the requirements of the authorities were concerned. In line with this, and bearing in mind that the arm's length principle should be preserved, the transfer price used in transactions between related parties should be comparable to the price that would have been used had the parties involved been independent. For this purpose, a related-party relationship, for tax purposes, is established where a minimum shareholding of 5% exists between the parties.
  • Handy Kurniawan Following the amendments of the law on general taxation provisions and Procedures (Law No. 28/2007), which took effect on January 1 2008) and the law on income tax (Law No. 36/2008), which came into effect on January 1 2009, the Indonesian government has amended the consumption tax law which is being well-known as value added tax (VAT) and luxury sales tax law (Law No. 42/2009) which will be effective from April 1 2010.
  • Bob van der Made In the European Commission's annual work programme for 2010, the Common Consolidated Corporate Tax Base (CCCTB) is included as a planned legislative proposal, aimed at making "tax rules simpler, reducing compliance costs and removing tax obstacles which companies currently suffer when they operate cross-border."
  • Stephanos Mitsios The recently enacted L. 3480/2010 is bringing about drastic changes in the tax environment of Greece. One of its most controversial provisions relates to the taxation of company profits.
  • David Cuellar Claudia Solano As part of Mexican efforts to avoid fiscal elusion and fraud, on September 1 2009 Mexico and the Kingdom of the Netherlands, in respect of the Netherlands Antilles, signed an agreement for the exchange of information on tax matters. This treaty was published in the Senate Gazette on April 29 2010 and it is now expected to be published in the Official Gazette in the near future.
  • The Swedish Parliament introduced new rules on cross-border contributions allowing Swedish parent companies to deduct a loss from a foreign subsidiary established within the European Economic Area (EEA).
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