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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.
Apparently, the IRS believes that the quality of transfer pricing documentation may have declined. (See its FAQ guidance issued in April...
The following article is part of a series of case studies and articles which have been kindly contributed by Dr. Harold McClure, a New-Y...
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...