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.
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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.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes: