Tag Archives: safe harbor

New Ukraine Transfer Pricing Rules
Transfer Pricing / Ukraine

New Ukraine Transfer Pricing Rules

Posted on by • Leave a comment

Prior to 2012, Ukraine had not been overly concerned about transfer pricing issues. But recently, in the era of fiscal deficits, the Ukrainian government has been more focused on implementing transfer pricing compliance practices in accordance with OECD member countries.  Transfer Pricing NEWS On December 4, 2012 the Parliament of Ukraine registered the draft bill … Continue reading →

Pros and Cons of Safe Harbors, and Advice to Tax Authorities
OECD / Transfer Pricing

Pros and Cons of Safe Harbors, and Advice to Tax Authorities

Posted on by • Leave a comment

Why is it worth weighing pros and cons of safe harbors*? Because the OECD’s June 6, 2012 draft endorses safe harbors and presents three sample memoranda that countries may use to negotiate bilateral safe harbors. Also, most would say that the IRS has been successful with instituting safe harbors on interest rates for intercompany loans, and … Continue reading →