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They are accountable for managing the flow of cross-border transactions within a multinational corporation (MNCs). We should determine the transfer cost for group companies at an arm's length rate, and that is the amount that a third party would be able to pay... #TransferPricing
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International Trade and Business Law I Trade Policy I Sustainability Consultant I Partner, MESA Advocates I International Consultant, COMESA
In the recent decision by the COMESA Competition Commission regarding the proposed acquisition of initially 69.67% and up to 80.89% of issued shares in Finance Trust Bank Limited by Access Bank PLC it was ruled that the parties pre & post merger market shares are not significant and the merged entity will not be a leading player in the banking sector in any of the defined relevant markets and hence not likely to hold a dominant position This is true because the banking sector in Uganda is not concentrated and is characterized by the existence of several players hence the merged entity will continue to face competition from other strong rivals post-merger. #competitionlaw #COMESA #mergers #competitionlawcaselaw #mergercaselaw
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What we are seeing from investor complaints, is that commonly it's related to sourcing fees taken upfront, which are being refused to be refunded. Make sure when deciding your fee structure, you are completely clear about it in your Terms of Business agreement, as well as written and verbally with any potential investor you're planning to work with. If everyone is clear and committed from the go on how your fees work, there will be no surprises for your investor further down the line - and hopefully as we gather more data on the sourcing sector - the number of complaints will not increase (or may even go down!) If you'd like to know more about how NAPSA works to educate sourcing agents and guide you through the compliance process - including guidance on fees - you can register with us for free (it takes about 60 seconds!) to get more information 👉 https://lnkd.in/eFjEcFYr Also check out our Guide to Fees below 👇 https://lnkd.in/ez2Bfy2h #sourcingfees #propertysourcing #dealsourcing #dealpackager #propertyinvestor #propertycomplaints #propertysector #propertybusiness #sourcingguide #napsauk
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Form and substance in transfer pricing: two sides of the same coin... #internationaltax #transferpricing #LCNLegal
Corporate lawyer and leading expert in the legal implementation of transfer pricing policies for multinational groups. Author of 'Intercompany Agreements for Transfer Pricing Compliance - A Practical Guide'.
Form and Substance in Transfer Pricing: Two Sides of the Same Coin. I really enjoyed attending TP Minds International this week, catching up with friends and meeting new ones. But one thing became apparent from some of the conversations and panel discussions: a confusion about the relationship between form and content in transfer pricing. The fundamental building block of transfer pricing is still transactional comparability. The first step of any TP analysis is therefore to identify the controlled transaction. In the context of any transaction, form and substance are two sides of the same coin. You can’t assess substance without having regard to form. Equally, the purported form of a transaction is meaningless without substance. The purpose of intercompany agreements – from a transfer pricing perspective – is to encapsulate both the form and the substance of a transaction. Relying on your ability to make it up after the event is not a great strategy. #TransferPricing #LegalSubstance #IntercompanyAgreements
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The SMSF Regulator's Bulletin 2020/1 provides compliance and tax guidance on SMSFs entering into arrangements relating to the purchase and development of real property. It states that investing in property development may require guidance from property lawyers, as investing in such assets can cause concerns if used inappropriately. Make sure your clients remain compliant with SMSF laws and regulations by visiting https://lnkd.in/gNQaJYyV #DBAAdvisory #smsfsetup #smsfadministration #smsf #selfmanagedsuper #smsfcompliance #superlaws #outsourcing
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OK, guys.... You have to check this out... it's a real game-changer! Meet Revenue Boost, a unified #payment optimization solution to help #merchants maximize conversions and minimize costs. To find out more click here: http://spr.ly/6044uKARn #RevenueBoost
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The Biden administration’s scrutiny now extends to noncompete clauses in the banking sector. The Federal Deposit Insurance(FDIC) has unveiled updated guidelines for bank mergers, proposing to outlaw noncompete agreements in employment contracts. #antitrust #bankmergers #mergersacquisitionsdivestitures #guidelines #noncompete
Biden Administration’s Labor Competition Focus Expands to Bank Noncompetes
https://www.pymnts.com
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The 2023 PPI Global Report is available to read on our website. The Global Report challenges your perspective about many transfer pricing practices in several countries, supported by members' experience. Thanks again to our members that shared their experience during the year to be a part of this report. #GlobalReport #PPI #Members #TransferPricing
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The focus from the ATO on SMSF Auditors has resulted in extreme reactions by some auditors who are now demanding independent valuations on small minority shareholdings in unlisted companies held by SMSF investors. This has some big implications for unlisted companies who now have shareholders wanting to sell just to get the shares out of their SMSF and avoid such ridiculous compliance issues. This is really bad for start ups and growth companies that have (or look for) SMSF investors. I know of several SMSFs that are trying to sell shares for this very reason - and this hurts the companies and wastes a lot of time and money. A common sense approach to auditing SMSFs is needed. A valuation needs to be supportable but if there is no reason to change it, then it needs to be allowed to stand without the Auditor immediately qualifying the audit (which is bad for SMSFs and their portfolio companies - and more work for the ATO).
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