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The following article is part of a series of case studies which have been kindly contributed by Dr Harold McClure, a New-York based econ...
On 18 May 2020, Spain’s Supreme Court has ruled that the Tax Administration can apply the penalty regime provided for in the General Tax...
One of the things I love about attending conferences like TP Minds International last week is that (as an adviser) you get insights into...
In the ‘bad old days’ of TP, many advisers appeared to take a fatalistic view of intangibles and intellectual property: the economic ana...
One misconception that we hear time and time again from well-meaning TP advisers is the recommendation of putting variables such as mark...
I’ve lost count of the number of transfer pricing articles I’ve read over the last couple of months which tell their readers to “review...
As I’m sure you already know, the OECD’s TP Guidelines already specify that master files and local files must include the following info...
Notre article pourrait commencer comme une histoire belge : « deux fiscalistes entrent dans une pièce, l’un français, l’autre belge ». M...
Until recently, we at LCN Legal weren’t aware that insurance was available in relation to transfer pricing risks. We thought you would b...
Last week, we were asked by the European management team of a substantial multinational group to advise on a very common scenario in the...
A short guide for transfer pricing and tax professionals on force majeure clauses in intercompany agreements and other key legal points...
It has been very encouraging to receive the news from Xiaofang’s family and from our friends that life in China is starting to open up a...