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 many high-…
Category: Tax Dispute Resolution
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 a multinat…
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 transfer prici…
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 of payments …
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 findings and…
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. Daniel N. Eras…
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 takeaways.
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 enterprises are …
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 method is partic…
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 transactions b…