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We are sometimes asked to include ‘Transfer pricing override’ clauses in intercompany agreements (ICAs). These clauses are intended to a...
Although we publish detailed checklists for intercompany agreements, and to a great extent ‘the devil is in the detail’, sometimes it’s...
Transfer pricing continues to be challenging for taxpayers and tax administrations, especially during the COVID-19 crisis.
SummaryIn May 2018 the UAE joined the Base Erosion and Profit Sharing (“BEPS”) framework. By joining the framework, is committed to impl...
The 4th of March, a new Dutch legislative proposal has been published for public consultation in order to prevent tax avoidance due to mis...
In one sense, the transfer pricing of every multinational group is set in stone. Unlike other aspects of transfer pricing documentation,...
On February 1st, Spain’s Official Gazette published the general guidelines of the Tax and Customs Control Plan for the year 2021. Follo...
In transfer pricing analysis, which prevails: the contractual terms of a related party transaction, or the economic substance?
The OECD’s guidance issued on 18 December 2020 on the Transfer Pricing implications of Covid (the ‘Covid Guidance’) may not have offered...
One of the perennial challenges in the legal implementation of transfer pricing policies is reconciling differing perspectives: those of...
The following article has been kindly contributed by Dr Harold McClure, a New-York based economist who has over 25 years of transfer pri...
In commercial relationships as in intra-group structures, there are two types of profit split arrangements.