Christos Theophilou and Demis Ioannou of Taxatelier present a case study of how the Cypriot tax authorities use safe harbour rules in determining arm’s-length interest rates.
Christos Theophilou and Costas Savva of Taxatelier consider how the OECD’s guidance on financial transactions and transfer pricing (FTTP) can be interpreted in consideration of intra-group loans.