Transfer pricing is probably one of the most important issues in international taxation. Transfer pricing happens whenever two companies that are part of the same multinational group trade with each other and establish a price for the transaction.
Transfer pricing as such is not illegal, however, it becomes illegal or abusive if transfer mispricing takes place to shift profits into low tax jurisdictions, also known as transfer pricing manipulation or abusive transfer pricing.
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Nowadays it is important to have ever increasing OECD Standards in mind to avoid possible Tax and Criminal Allegations through non-compliant and validated Corporate Structures. Speak to us to find out your Alternatives.
It is surely not forbidden to own an Offshore Company for a legitimate purpose. However, if the only purpose of your Offshore entity is Tax Avoidance or even worse Tax Evasion, you should reconsider all options.
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Action 3 of the BEPS ACTION PLAN stresses the need to address base erosion and profit shifting using a controlled foreign company (CFC) rules. Many countries already have CFC rules, but these rules do not always counter BEPS in a comprehensive manner.
While CFC rules in principle lead to inclusions in the residence country of the ultimate parent, they also have positive spillover effects in source countries because taxpayers have no (or much less of an) incentive to shift profits into a third, low-tax jurisdiction.
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