Multi-country Webinar: Are your loans at arm’s length?

Taxand Cyprus participated in the webinar with subject “Are your loans at arm’s length? organized by Taxand Mauritius (IQ-EQ Mauritius)

With ongoing economic globalisation and the repercussions of the Covid-19 pandemic on traditional business models, intra group loans have become increasingly important for the survival of group companies. With the increase in related party loans, transfer pricing is becoming more significant as tax authorities emphasise on whether these transactions are at arm’s length.

The OCED’s Transfer Pricing Guidance on Financial Transactions provides specific guidance on the Transfer Pricing aspects of financial transactions which is a highly disputed area between taxpayers and tax authorities. The Mauritian Government has, in recent year’s national budgets, announced its intention of formalising the TP framework for the country.

Christos Theophilou
Christos specialises in private clients and corporate tax issues (including transfer pricing) with an international dimension, such as private equity structuring, cross-border investments, structured finance, IP structuring and international trade. Christos received his Master of Laws (MSc) in Tax Law from Oxford University. He holds an LLB Law, a Bachelor’s degree in Economics, the Advanced Diploma in International Taxation (ADIT) of the UK Chartered Institute of Taxation, as well as being a qualified Chartered Accountant in England & Wales. Christos is a contributor to international tax publications such as IBFD, Tax Notes lnternational, Bloomberg ΒΝΑ, International Tax Review and IFA as a national reporter. Furthermore, Christos is currently a member of the Τax Policy and Strategy committee of lnstitute of Certified Public Accountants of Cyprus. Christos is also a freelance lecturer for Τolley’s (LexisNexis) in Greece, Cyprus and Ukraine, where his main areas are ADIT Paper 1 Principles of lnternational Tax.

Gaspar Lopes Dias
Gaspar has experience in a broad range of transfer pricing and international tax matters including financial operations, business reorganisations and IP structuring, advising multinationals in various industries and investment funds. He joined Taxand Cyprus in 2021 from the tax practice of Baker & McKenzie in London, having previously worked at Loyens & Loeff in Luxembourg, and KPMG Belgium. Gaspar holds an LL.B civil law (Nova University Lisbon), LL.M International Tax (Tilburg University), MSc Taxation (University of Oxford), ADIT member UK CIOT, and is an IFA member (UK Branch).

Feroz Hematally
Feroz is the Head of Tax for IQ EQ Mauritius and Director of Taxand Mauritius. Feroz is a seasoned tax professional with over 20 years’ experience spanning roles in Mauritius and UK. He joined IQ-EQ after spending over 9 years leading Tax Compliance, Advisory and Technical Training at PwC Mauritius. Prior to joining PwC Mauritius, he spent 13 years in London. He trained in Corporate Tax with EY London and subsequently was the UK Tax Compliance Manager for Invensys Plc, a FTSE 100 Group listed on the London Stock Exchange. Feroz is an FCA and also holds a Practising Certificate from the ICAEW.