Dr Daniel N Erasmus

Keysight Technologies v. Malaysia: Implications for Transfer Pricing and Tax Compliance

The Keysight Technologies Malaysia case underscores the complexities of transfer pricing and tax compliance. By understanding the court’s findings and implementing robust tax risk management strategies, companies can better navigate similar disputes and ensure compliance with tax regulations.

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Understanding the Profit Split Method (PSM) in Transfer Pricing

The Profit Split Method in Transfer Pricing is a crucial approach used to ensure that transactions between related companies are conducted at arm’s length, meaning at fair market value. This method is particularly useful in scenarios where transactions are highly integrated and cannot be evaluated separately.

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Understanding the Transactional Net Margin Method (TNMM) in Transfer Pricing

The Transactional Net Margin Method (TNMM) is a pivotal tool in transfer pricing, used to ensure that transactions between associated enterprises are conducted at arm’s length. This method compares the net profit margin of a taxpayer from a controlled transaction with that of comparable uncontrolled transactions.

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The Cost Plus Method in Transfer Pricing

The Cost Plus Method is a widely used approach in transfer pricing for determining arm’s length prices between related entities. This method is particularly useful for manufacturers, service providers, and other businesses that add value to goods or services before transferring them to related parties.

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Luxembourg vs “LLC AB”: Luxembourg Court Upholds Debt Classification of Interest-Free Loan in Transfer Pricing Case

Luxembourg court rules interest-free loan qualifies as debt, allowing notional interest deduction in landmark transfer pricing case with implications for multinationals.

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