India vs AON Consulting: TRANSFER PRICING CASE
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax – 1 and Ors. (ITA 244/2024), addressed a …
Tag: OECD
Kenya vs Avic International: TRANSFER PRICING CASE
The Tax Appeals Tribunal in Kenya ruled on the case involving AVIC International Beijing (EA) Limited (Appellant) and the Commissioner of Domestic Tax…
Australia vs SNF: In-Depth Summary
The case Commissioner of Taxation v. SNF (Australia) Pty Ltd concerned a dispute over the application of the arm's length principle in the context of …
What is Comparability Analysis in Transfer Pricing?
Comparability Analysis in Transfer Pricing is a cornerstone of ensuring that transactions between related parties in multinational enterprises (MNEs) …
The Italian Supreme Court’s Landmark Ruling on Loss-Making Entities: My Take
In August 2024, the Italian Supreme Court delivered a pivotal ruling on transfer pricing, specifically addressing the inclusion of loss-making entitie…
The OECD’s Transfer Pricing Framework for Mineral Pricing
Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a comprehensive framewo…
Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in Comparability Analyses
The Italian Supreme Court's 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guideli…
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…
Creating a Master File for Transfer Pricing Documentation
Discover best practices for creating a comprehensive transfer pricing master file to comply with documentation requirements for multinational enterpri…