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Paula Ruffell and Astrid Vroom (EY) consider the implications of Refinitiv to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.
Joel Cooper and Paula Ruffell (EY) outline the steps to consider if a ‘protective’ discovery assessment is issued for a transfer pricing matter.
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.
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 (LCN Legal) and Philip de Homont (Nera Economic Consulting) set out a framework when considering the allocation of risks in transfer pricing.
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.
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).
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 (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.