Transfer Pricing

A recent ruling in GE Money Financial Services Pvt. Ltd. v. DCIT, the Income Tax Appellate Tribunal (ITAT) has further contributed to the uncertainties in Transfer Pricing in India. The ruling is a…

In the EU Commission’s view a tax ruling (hereinafter “APA”) confers on the beneficiary a selective advantage under Art. 107(1) of the Treaty on the Functioning of the European Union (hereinafter …

Publication of text of The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) by the OECD on 24 November 2016 is one of the…

There are many things in life that we take for certainties, which are not, e.g. that it was the Scots that invented whiskey, the French champagne, or the Italians pizza.  All not necessarily true…

To refresh memories, several months ago I posted part 1 of this study on Kluwer's International Tax Blog: Application of TNMM to Starbucks Roasting Operation: Seeking Comparables Through…

Brazil is known for its unique transfer pricing legislation. While in most countries the use of comparables is central for the application of the transfer pricing methods, the Brazilian system has…

Random thoughts on presumptions on accuracy It is a fact that most in-house tax professionals know very little about their group’s financial systems.  E.g. very few know whether their companies…

A considerable increase of transfer pricing disputes could be observed in Italy over the last decade. Notwithstanding the rising trend of proceedings activated by the Tax Authorities and further…

On 24 August 2016, the US Treasury Department issued a White Paper on “The European Commission’s Recent State Aid Investigations of Transfer Pricing Rules” (the “White Paper”), denouncing the…