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The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more
On August 12, 2015, the IRS issued Rev. Proc. 2015-41, which sets out the procedures for pursuing advance pricing agreements (APAs). The new revenue procedure replaces Rev. Proc. 2006-9 and finalizes revenue procedures...more
The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more
The following sets out a summary of recently announced major changes affecting the transfer pricing policy of certain French companies. New Provisions of French Law - Provisions Already Adopted - Within the...more
Recently enacted Russian transfer pricing rules now require companies operating in Russia to file annual documentation in compliance with new regulatory guidance regarding related foreign party and certain domestic party...more
On 13 February 2013, the Federal Government introduced legislation into Parliament that will significantly broaden the circumstances in which Australia's transfer pricing rules may be applied. The legislation will come...more