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
Taxing Times: introducing ITR’s new monthly podcast
Our first instalment features analysis of Deloitte’s landmark EMEA merger, Donald Trump’s Supreme Court tariff showdown and Venezuela’s tax evolution
TP documentation in a fragmented world: how to limit audit triggers
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
A&M Tax launches dedicated pillar two, TP team in Saudi Arabia
The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
Advisers clash over Venezuela’s TP evolution in post-Maduro world
Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
Italy: Guide to TP method selection in transactions involving intangibles
Federico Vincenti and Carola Valente Della Rovere of Valente Associati GEB Partners/Crowe Valente examine the challenges and methodologies involved in determining arm’s-length prices for transactions involving intangible assets, addressing how to ensure compliance and mitigate tax risks