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A ‘swimming pool’ clause may be appropriate in a Transfer Pricing context whenever there is an intercompany supply of services, and the ac...
The concept of ‘recourse’ is key to understanding risk allocation in intercompany agreements.
For regulated groups such as those in the financial services sector, regulatory considerations usually ‘trump’ transfer pricing optimisati...
As you may know, every Monday we send out an e-newsletter with insights, guidance, and views on the legal implementation of transfer pri...
Thanks very much to everyone who attended our recent interactive webinar on the basics of intercompany agreements for financial transact...
This week I’d like to draw your attention to a Resolution of the Administrative Tax Court of Panama of 9 July 2021, which set a precedent fo...
Every Monday we send out an email with insights, guidance, and views on the legal implementation of transfer pricing for multinational group...
Some TP methods – specifically, the cost-plus method – imply a specific drafting structure for pricing clauses in intercompany agreement...
This is one of the most common questions which come up at the training sessions we run on intercompany agreements for TP compliance.
This is a sensitive subject for many TP advisers.
In one sense, the transfer pricing of every multinational group is set in stone. Unlike other aspects of transfer pricing documentation,...
Apparently, the IRS believes that the quality of transfer pricing documentation may have declined. (See its FAQ guidance issued in April...