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Tag: Transfer pricing adjustments

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Analyse de marchéAnalyse de marché MarketsMarkets

Intangible Asset Shifting (IAS) Module

The Real Asset Shifting (RAS) module (www.steelldy-indices.com) focuses on tangible assets, notably cross-border real estate. However, intangible assets (patents, trademarks, software, know-how, databases, client lists) are historically the main channel for profit shifting in multinational groups. Unlike tangible assets, intangibles do not significantly benefit from the Substance-based Income Exclusion (SBIE), are highly sensitive to transfer…
13 hours ago0Comments

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Papers with financial graphs beside stacks of US dollar bills representing market analytics.
Analyse de marchéAnalyse de marché MarketsMarkets

How High-Value Properties Slash Pillar Two Top-Up Tax Under SBIE Rules

The Substance-based Income Exclusion (SBIE) is a carve-out mechanism under Pillar Two (GloBE) that excludes part of a jurisdiction's GloBE Income before calculating top-up tax, recognizing real economic substance. Its formula for 2022 rules with 2024-2026 guidance is 5% of eligible payroll plus 5% of tangible assets' carrying value. Payroll includes eligible employee expenses,…
1 day ago0Comments

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