Analysis of BlackRock HoldCo 5, LLC v HMRC: Transfer Pricing and Unallowable Purpose Test
Explore the key aspects and implications of the BlackRock HoldCo 5, LLC v HMRC case, focusing on transfer pricing and the unallowable purpose test.
Tag: tp methods
What is the most common Transfer Pricing Method? The Transactional Net Margin Method Explained
Uncover the essentials of the Transactional Net Margin Method, the most common transfer pricing strategy for global businesses.
Eaton Corporation vs. IRS: Transfer Pricing Dispute
Eaton Corporation, a global manufacturer of electrical and industrial products, faced significant tax disputes with the IRS regarding its transfer pri…
Ferragamo France Transfer Pricing Case: Key Lessons for Luxury Brands
The Ferragamo France transfer pricing case offers valuable insights for luxury goods companies. This landmark ruling highlights the complexities of tr…
Transfer Pricing Dispute Between Australia and Glencore Investment Pty Ltd
Glencore Australia (CMPL) sold copper concentrate produced in Australia to its Swiss parent, Glencore International AG (GIAG).
The tax authorities …
Coca-Cola vs. IRS: Landmark Transfer Pricing Dispute
The Coca-Cola transfer pricing dispute is a landmark case between The Coca-Cola Company (TCCC) and the Internal Revenue Service (IRS). The case center…
GlaxoSmithKline v. CIR (Philippines)
In GlaxoSmithKline (GSK) Philippines, Inc. v. Commissioner of Internal Revenue (CIR), the Supreme Court of the Philippines upheld a tax deficiency ass…
GlaxoSmithKline vs Canada: Transfer Pricing Case
he GlaxoSmithKline transfer pricing case was a landmark decision in Canadian tax law. It involved GSK's Canadian subsidiary and the Canada Revenue Age…