The Transfer Pricing Compliance Assurance – An End-to-End Toolkit developed by the United Nations Subcommittee on Transfer Pricing is a comprehensive guide designed to support tax administrations, particularly in developing countries, in ensuring efficient and effective transfer pricing compliance.
Optimised Transfer Pricing Compliance: UNs End-to-End Toolkit Read More »
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd (ATTL) v/s Director General of the MRA.
Avago Technologies Trading Ltd v/s Director General, MRA Judgment Read More »
The importance of organizational structure and business overview in transfer pricing documentation cannot be overstated. These elements provide the foundation for accurate and defensible transfer pricing practices.
Transfer pricing policies and methodologies are critical components of transfer pricing documentation, which is essential for multinational corporations (MNCs) to ensure tax compliance and avoid profit shifting.
Transfer Pricing Policies and Methodologies in Transfer Pricing Documentation Read More »
The importance of financial data and calculations in transfer pricing documentation cannot be overstated. Accurate financial information forms the backbone of any robust transfer pricing analysis, ensuring compliance with tax regulations and mitigating risks associated with cross-border transactions.
Importance of Financial Data and Calculations in Transfer Pricing Documentation Read More »
Intra-group losses in transfer pricing have become a focal point of legal scrutiny and regulatory enforcement. The recent cases of Dart Sudamericana, ST Dupont, and Stora Enso highlight the complexities and challenges multinational enterprises (MNEs) face in justifying and managing these losses.
Understanding Intra-Group Losses in Transfer Pricing: Key Insights from Recent Cases Read More »
Transfer pricing continues to be a critical issue for multinational corporations. The resale price method (RPM) plays a significant role in many high-profile cases. This article examines the importance of RPM in four major transfer pricing disputes and offers insights for better managing these risks.
The Resale Price Method in Major Transfer Pricing Cases Read More »
Intercompany agreements and contracts are critical elements in transfer pricing, ensuring that transactions between related entities within a multinational enterprise (MNE) comply with the arm’s length principle.
Intercompany Agreements and Contracts in Transfer Pricing Documentation Read More »
The Dow Chemical Canada case underscores the complex interplay between tax law, administrative discretion, and jurisdictional issues in transfer pricing disputes.
Dow Chemical Canada ULC v. The King: Tax Court Jurisdiction in Transfer Pricing Disputes Read More »
The Federal Court of Australia’s judgment in PepsiCo, Inc v Commissioner of Taxation provides critical insights into the characterization of payments under intercompany agreements and the application of tax laws.
PepsiCo v Australia: Implications for Royalty Withholding Tax and Diverted Profits Tax Read More »
