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 …
Tag: TNMM
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…
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, …
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 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 at arm's le…
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…
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 tax authori…
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 international…