Denmark vs Accenture: Transfer Pricing Case
The Danish Supreme Court rendered its decision in the case of Accenture A/S v. Danish Ministry of Taxation, upholding the lower court’s judgment. Th…
Category: Transfer Pricing Methods
Understanding the Comparable Profit Method (CPM) in Transfer Pricing
The Comparable Profit Method (CPM) is a widely used approach in transfer pricing, employed to ensure that transactions between related entities (often…
Avago Technologies Trading Ltd v/s Director General, MRA Judgment
The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd (ATTL) v/s…
The Importance of Organizational Structure and Business Overview in Transfer Pricing Documentation
The importance of organizational structure and business overview in transfer pricing documentation cannot be overstated. These elements provide the fo…
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 corporatio…
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 forms the bac…
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 Sudamericana, …
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-…
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…