Announcement: Online Transfer Pricing Conference Focused on Africa
The Academy of Tax Law is excited to announce an online Transfer Pricing Conference specifically emphasising Africa. This event will take place in Nov…
Category: International Tax
Exchange of information on reportable cross-border tax arrangements: CJEU Judgment in Case C-623/22
The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the validity of c…
Optimised Transfer Pricing Compliance: UNs End-to-End Toolkit
The Transfer Pricing Compliance Assurance – An End-to-End Toolkit developed by the United Nations Subcommittee on Transfer Pricing is a comprehensiv…
The Importance of Organizational Structure and Business Overview in Transfer Pricing Documentation
The importance of organizational structure and business overview in transfer pricing documentation cannot be overstated. These elements provide the fo…
Transfer Pricing Policies and Methodologies in Transfer Pricing Documentation
Transfer pricing policies and methodologies are critical components of transfer pricing documentation, which is essential for multinational corporatio…
Importance of Financial Data and Calculations in Transfer Pricing Documentation
The importance of financial data and calculations in transfer pricing documentation cannot be overstated. Accurate financial information forms the bac…
Understanding Intra-Group Losses in Transfer Pricing: Key Insights from Recent Cases
Intra-group losses in transfer pricing have become a focal point of legal scrutiny and regulatory enforcement. The recent cases of Dart Sudamericana, …
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-…
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…