Canada’s elimination of the TP nonrecognition and replacement rule: implications for taxpayers
Ross Harris of Doane Grant Thornton explains how Canadian transfer pricing amendments increase recharacterisation risk and heighten the need for robust documentation and transaction design
From cost-plus to value-driven: rethinking transfer pricing for high value-adding intra-group services
Michael Cedercrantz of Skeppsbron Skatt comments on the expected update of Chapter VII of the OECD Transfer Pricing Guidelines and the introduction of the high value-adding services concept
‘Clear limitations’: Italian advisers differ on intra-group financing TP ruling
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
Back office to backbone: tax risks of evolving global capability centres
As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management
Italy: Selection of TP methods in transactions involving software distribution
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente analyse how intragroup software distribution transactions are classified and transfer pricing methods applied, focusing on the interaction between OECD guidance, Italian legislation, and case law
Australian case highlights importance of documenting related-party transactions
Kelvin Yuen and Suhani Mehra of DLA Piper Australia examine a Full Federal Court decision denying deductions for undocumented intragroup service fees, and the risks of relying on inferred contracts in related-party transactions
HMRC almost doubles revenue from TP cases in one year
Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
Is Coca-Cola’s ‘Black Swan’ event in sight?
As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency
TP audits in the MENA region: from low-risk perception to high-stakes enforcement
Mithilesh Reddy of Steadfast Business Consulting says multinationals must adopt proactive governance and robust compliance practices as the region’s transfer pricing environment develops at pace
When EU directives displace tax treaties: a controversial interpretation of EU law primacy
Rafael Calvo Salinero and Fernando Brioso de la Rica of Garrigues examine the implications of a Spanish Supreme Court ruling on treaty relief when the Interest and Royalties Directive exemption is denied