The Resale Price Method in Major Transfer Pricing Cases
Transfer pricing continues to be a critical issue for multinational corporations. The resale price method (RPM) plays a significant role in many high-…
Category: Dispute Resolution
Intercompany Agreements and Contracts in Transfer Pricing Documentation
Intercompany agreements and contracts are critical elements in transfer pricing, ensuring that transactions between related entities within a multinat…
Dow Chemical Canada ULC v. The King: Tax Court Jurisdiction in Transfer Pricing Disputes
The Dow Chemical Canada case underscores the complex interplay between tax law, administrative discretion, and jurisdictional issues in transfer prici…
PepsiCo v Australia: Implications for Royalty Withholding Tax and Diverted Profits Tax
The Federal Court of Australia's judgment in PepsiCo, Inc v Commissioner of Taxation provides critical insights into the characterization of payments …
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 le…
Danish Supreme Court Upholds Transfer Pricing Adjustment in Maersk Oil Case
Summary of the Danish Supreme Court's landmark ruling on transfer pricing in the Maersk Oil case, with implications for multinationals and tax authori…
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 …
The Importance of Thorough Economic Analysis in Transfer Pricing
Discover why thorough economic analysis in transfer pricing is essential for compliance and profit optimization. Learn how experts like TRM can help.
Poulter vs SARS: Taxpayer’s Right to Non-Legal Representation
In the landmark case of Poulter v CSars the Western Cape High Court clarified an essential aspect of taxpayers' rights in South Africa. This case revo…
CUP vs TNMM in Italy vs DG: A Transfer Pricing Method Analysis
Analyze the Italy vs DG transfer pricing case, comparing CUP and TNMM methods from tax authority and taxpayer perspectives. Insights from Prof. Dr. Er…