Global association of transfer pricing and valuation consulting firms with presence in the most entrepreneurial cities around the globe.
Some TP methods – specifically, the cost-plus method – imply a specific drafting structure for pricing clauses in intercompany agreement...
The Plenary of the Supreme Federal Court (STF) decided, on Thursday (13), that the exclusion of the Tax on Circulation of Goods and Servic...
This is one of the most common questions which come up at the training sessions we run on intercompany agreements for TP compliance.
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...
This is a sensitive subject for many TP advisers.
European Union has reached a preliminary agreement to give Turkey more time to meet tax transparency requirements. To avoi...
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...