Insights

The Arm’s Length Principle (ALP) is the foundation of international transfer pricing rules, as set out in the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. It ensures that transactions between associated enterprises are priced as if they were conducted between independent entities under comparable circumstances. This principle prevents profit shifting and tax base erosion by aligning taxable profits with economic activity and value cr

Legal Notice 284 of 2022 introduced Transfer Pricing Rules (TPR) in Malta. The rules apply as from basis years starting on or after 1st January 2024 and with respect to arrangements that are either newly entered into after 1st January 2024 or are materially altered on or after that date. The rules will apply to all cross-border transactions (domestic transactions are excluded from the scope of the TPR) between associated enterprises, even if there has not been any material al

One of the biggest hurdles in ESG reporting has always been data—collecting it across complex supply chains, ensuring consistency, and presenting it in a way that investors and regulators trust. With the EU’s CSRD and similar regulations demanding detailed, auditable disclosures, the stakes have never been higher. This is where Artificial Intelligence (AI) has entered the ESG conversation.

In the setup stage, enterprises need cash to invest in the assets (physical, intellectual) and human capital that will eventually generate the profits of the enterprise. Without a well-planned cash strategy that establishes how the business is to be funded and provides for contingencies, few enterprises manage to make it past the first year.