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On 5 January 2023 the Cyprus Tax department (CTD) issued a circular (1/2023) which terminates the application of “safe harbours” on back-t...
The Brazilian government has enacted new transfer pricing (PT) legislation based on the arm's length principle, in accordance with the Org...
Five reasons multinational enterprises should review their transfer pricing positions!
The U.S. Tax Court in the case of Whirlpool Financial Corp. v. Commissioner, Nos. 1899/1900 upheld the Internal Revenue Service’s (IRS)...
Today Multinational organizations are facing various challenges due to stringent transfer pricing audits from the tax authorities global...
Recently the U S Tax Court issued its second opinion in the case of Medtronic, Inc and Consolidated Subsidiaries vs Commissioner for det...
In recent years, transfer pricing audits have become more common in the United States, with the Internal Revenue Service (IRS) taking a...
Organisation for Economic Co-operation and Development (OECD) published the sixth annual progress report of the OECD/G20 Inclusive Framewo...
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.
In the third part of a series, Parwin Dina of Global Tax Services considers some interesting aspects of the upcoming corporate income tax...
For regulated groups such as those in the financial services sector, regulatory considerations usually ‘trump’ transfer pricing optimisati...