Transfer Pricing

Climate change and the use of natural resources present us all with a major challenge. We all have our part in it and we can all contribute to ensure that we do not live at the expense of future…

Executive summary: When we look at the digital economy, we tend to think of it as a global, intangible and knowledge-driven system. However, the digital economy is not only driven by patents or…

Energy security and energy prices have become one of the biggest economic challenges for the world right after the global pandemic. Commodity prices for coal, oil and gas increased sharply in 2022.[1…

State aid law is closely linked to the Treaty on the Functioning of the European Union (TFEU) commitment to creating, maintaining, and strengthening a common market in which competition is not…

"It follows that only the national law applicable in the Member State concerned must be taken into account in order to identify the reference system for direct taxation, that identification being…

On August 25, 2022, the Sixth Circuit Court of Appeals answered a fundamental question about advance pricing agreements (APAs): Is an APA a contract between the IRS and a taxpayer?[1] If it is a…

On Thursday, August 18, 2022, Chief Judge Kathleen Kerrigan of the U.S. Tax Court published her 75-page decision on the Medtronic and I.R.S. controversy (“Medtronic III”).[1] This decision resulted…

Two years on since Chapter X of the OECD Transfer Pricing Guidelines (Chapter X) was published in February 2020, the practical transfer pricing aspects of financial transactions are due another look…

  A conversation on International Tax Practice culminated into an IFA webinar series on May 20th with global experts sharing their perspectives on landmark treaty and transfer pricing rulings…