Transfer pricing (TP) rules have been present for more than a decade in the Albanian Corporate Income Tax (CIT) Law, but specific and detailed regulations on the application of these rules were only published in the Official Journal No. 70, dated May 20 2014. These changes have totally transformed Article 36 of the Law on Income Tax (No. 8438, dated December 28 1998) by adding seven more provisions on specific rules and actions.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap