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Latest tax posts

Commentary, playbooks and updates from the Academy and its faculty.

640 articles

Transfer Pricing Policies and Methodologies in Transfer Pricing Documentation

Transfer pricing policies and methodologies are critical components of transfer pricing documentation, which is essential for multinational…

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Importance of Financial Data and Calculations in Transfer Pricing Documentation

The importance of financial data and calculations in transfer pricing documentation cannot be overstated. Accurate financial information…

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Understanding Intra-Group Losses in Transfer Pricing: Key Insights from Recent Cases

Intra-group losses in transfer pricing have become a focal point of legal scrutiny and regulatory enforcement. The recent cases of Dart…

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The Resale Price Method in Major Transfer Pricing Cases

Transfer pricing continues to be a critical issue for multinational corporations. The resale price method (RPM) plays a significant role in…

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Intercompany Agreements and Contracts in Transfer Pricing Documentation

Intercompany agreements and contracts are critical elements in transfer pricing, ensuring that transactions between related entities within…

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Dow Chemical Canada ULC v. The King: Tax Court Jurisdiction in Transfer Pricing Disputes

The Dow Chemical Canada case underscores the complex interplay between tax law, administrative discretion, and jurisdictional issues in…

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PepsiCo v Australia: Implications for Royalty Withholding Tax and Diverted Profits Tax

The Federal Court of Australia’s judgment in PepsiCo, Inc v Commissioner of Taxation provides critical insights into the characterization…

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Keysight Technologies v. Malaysia: Implications for Transfer Pricing and Tax Compliance

The Keysight Technologies Malaysia case underscores the complexities of transfer pricing and tax compliance. By understanding the court’s…

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Understanding Non-Recognition in Transfer Pricing

Explore non-recognition in transfer pricing through landmark cases from Malaysia, Luxembourg, and Denmark. Expert analysis by Prof. Dr.…

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Malaysia Transfer Pricing Case: Watsons Personal Care Stores vs Tax Authorities

Summary of Malaysian transfer pricing case of Watsons Personal Care Stores vs tax authorities, its implications for multinationals, and key…

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Understanding the Profit Split Method (PSM) in Transfer Pricing

The Profit Split Method in Transfer Pricing is a crucial approach used to ensure that transactions between related companies are conducted…

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Understanding the Transactional Net Margin Method (TNMM) in Transfer Pricing

The Transactional Net Margin Method (TNMM) is a pivotal tool in transfer pricing, used to ensure that transactions between associated…

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The Cost Plus Method in Transfer Pricing

The Cost Plus Method is a widely used approach in transfer pricing for determining arm’s length prices between related entities. This…

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Understanding the Comparable Uncontrolled Price (CUP) Method in Transfer Pricing

The Comparable Uncontrolled Price (CUP) Method is one of the primary transfer pricing methods used to determine arm’s length prices for…

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Danish Supreme Court Upholds Transfer Pricing Adjustment in Maersk Oil Case

Summary of the Danish Supreme Court’s landmark ruling on transfer pricing in the Maersk Oil case, with implications for multinationals and…

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Understanding the Resale Price Method in Transfer Pricing

The Resale Price Method in Transfer Pricing is a fundamental approach used by multinational enterprises (MNEs) to ensure compliance with…

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Luxembourg vs “LLC AB”: Luxembourg Court Upholds Debt Classification of Interest-Free Loan in…

Luxembourg court rules interest-free loan qualifies as debt, allowing notional interest deduction in landmark transfer pricing case with…

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The Arm’s Length Principle in Transfer Pricing

Learn about the Arm’s Length Principle in Transfer Pricing, its importance, methods, and why consulting experts like TRM is crucial for…

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Understanding the Burden of Proof in Transfer Pricing: Insights from Recent Court Cases

Explore the critical role of the burden of proof in transfer pricing through analysis of recent Dutch, Czech, and Italian court cases.

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Netherlands vs “Lux Credit B.V. – Ruling on Arm’s Length Principle in Intra-Group Financing Case

Analysis of Dutch court ruling on arm’s length principle in intra-group financing. Key insights for multinationals on transfer pricing and…

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The Importance of Thorough Economic Analysis in Transfer Pricing

Discover why thorough economic analysis in transfer pricing is essential for compliance and profit optimization. Learn how experts like TRM…

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Czech Transfer Pricing Case Highlights Importance of Burden of Proof

Analysis of the ERT Automotive Bohemia case emphasizses the critical role of the burden of proof in transfer pricing disputes and its…

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Czech Transfer Pricing Case: ERT Automotive Bohemia Wins Appeal Against Tax Authorities

Analysis of the Czech transfer pricing case where ERT Automotive Bohemia won against tax authorities, highlighting key issues and…

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Poulter vs SARS: Taxpayer’s Right to Non-Legal Representation

In the landmark case of Poulter v CSars the Western Cape High Court clarified an essential aspect of taxpayers’ rights in South Africa.…

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