TRANSFER PRICING

David Murphy

David Murphy (BSI Group) explains why, for transfer pricing purposes, the cost influence curve could be a rational starting point for contribution analysis when allocating residual profits.

Pierre-Antoine Klethi

Peter Adriaansen

This judgment deals a blow to the European Commission’s state aid investigations concerning tax rulings on transfer pricing, writes Pierre-Antoine Klethi and Peter Adriaansen (Loyens & Loeff).

Paul Sutton

Philip de Homont

Paul Sutton (LCN Legal) and Philip de Homont (Nera Economic Consulting) set out a framework when considering the allocation of risks in transfer pricing.

Batanayi Katongera

Sarah Bond

Batanayi Katongera (in-house specialist) and Sarah Bond (Freshfields Bruckhaus Deringer) discuss whether the UK terms should be given the broader meaning of the OECD concepts in order to bring greater clarity and reduce the risk of double taxation.

Paul Sutton

The Upper Tribunal’s decision on the transfer pricing aspects of the BlackRock case is an overly restrictive interpretation of the law, writes Paul Sutton (LCN Legal).

Vladimir Milic

Anton Hume

The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).

Sarah Bond

Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.

Five key lessons from the OECD’s new guidance.

Selena Schneider, John W. Lamszus, Daniel J. Pugh

Selena Schneider, John W. Lamszus and Daniel J. Pugh (Crowe) provide a guide to this common treasury management tool used by multinationals to efficiently manage cash and reduce process and transaction costs.