International Taxation

Transfer Pricing

Transfer pricing is a profit allocation method used to attribute an MNE’s net income (profit or loss) to the tax jurisdictions where it operates its subsidiary controlled foreign corporations (CFCs). The transfer price is defined as the price charged between related corporate entities for goods or services in an intercompany transaction.

International Taxation

International taxation refers to treaty provisions relieving international double taxation. In broader terms, in includes domestic legislation covering foreign income of residents (worldwide income) and domestic income of non-residents.