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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...
We often get asked whether it is legally possible to backdate intercompany agreements. (Answer: it depends.) But what about backdating of tr...
We hope that you found our recent analysis of the BlackRock decision to be thought-provoking and useful. This concluded that while the j...
As you may know, every Monday we send out an e-newsletter with insights, guidance, and views on the legal implementation of transfer pri...
Sometimes, expressions used in transfer pricing reports are so vague that they may conceal more than they reveal. One example is the term 'm...
Thanks very much to everyone who attended our recent interactive webinar on the basics of intercompany agreements for financial transact...
As of 1 January this year, 24 of the 35 LIBOR interest rate benchmarks or ‘settings’ are no longer published.What does this mean for groups...
Last year, the US Tax Court's decision in the Coca-Cola case sent shockwaves through the tax and transfer pricing community. USD 12 billion...
We hope you enjoyed our recent interview with Philippe Paumier. We found it very thought-provoking, and in fact, we'd like to share some of...
We're sure you agree that huge, eye-catching changes will only be part of the solution to the climate crisis. It is just as important th...