A cash pooling case from Denmark suggests that transfer prices should be applied on a net basis, while a Dutch ruling on captive insurance companies underlines the need to have appropriate functions to establish substance. In the United States, the Internal Revenue Service has issued an interesting guide on how it conducts transfer pricing audits.
90a1d87b-c1b5-43c3-a720-cd324830adee.tmb-editorspic.jpg?sfvrsn=1b2d0a7e_1)
