Tax authorities using CUPs for pricing transactions

March 12 2013

Matthew Wall and David Jarczyk explain the new trend where tax authorities use third party agreements to test, and adjust if needed, the arm’s length price of related party transactions.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

News Transfer Pricing

more across site & shared bottom lb ros

More from across our site

Indirect Tax

Advisers hope Brazil and US reach agreement on Trump tariffs

The threat of 50% tariffs on Brazilian goods coincides with new Brazilian legal powers to adopt retaliatory economic measures, local experts tell ITR

Sam Sholli, July 18 2025

Direct Tax

germany berlin reichstag building german parliament bundestag - Concept piece for power, authority, economy, performance, government, planning and control.

This week in tax: Germany still ‘committed’ to pillar two despite chancellor’s condemnation

The country’s chancellor appears to have backtracked from previous pillar two scepticism; in other news, Donald Trump threatened Russia with 100% tariffs

Tom Baker, July 18 2025

Direct Tax

OECD unveils pillar two safe harbour for highly taxed MNEs

In its latest G20 update, the OECD also revealed tense discussions with the US where the ‘significant threat’ of Section 899 was highlighted

Tom Baker, July 17 2025

Direct Tax

Too many HMRC compliance investigations last too long, committee warns

The tax agency has increased compliance yield from wealthy individuals but cannot identify how much tax is paid by UK billionaires, the committee also claimed

Sam Sholli, July 17 2025

Transfer Pricing

UK TP proposals could ‘double compliance costs’, tax firm warns

Saffery cautioned that documentation requirements in new government proposals must be limited if medium-sized companies are not exempted from TP

Tom Baker, July 16 2025

Direct Tax

Pillar two no longer has a future, German chancellor claims

The global minimum tax deal is not viable without US participation, Friedrich Merz has argued

Sam Sholli, July 16 2025

Direct Tax

Pillar two is revising global tax competition with a 15% minimum tax rate

Future of pillar two uncertain after Section 899 withdrawal averts ‘catastrophe’

Section 899 of the ‘one big beautiful’ bill would have spelled disaster for many international investors into the US, but following its shelving, attention turns to the fate of the OECD’s pillars

Ralph Cunningham, July 16 2025

Direct Tax

‘Pro bono is a must’: Amory Heine on giving back

DLA Piper’s co-head of tax for the US and Latin America tells ITR about her fervent belief in equal access to the law, loving yoga, and paternal inspirations

July 15 2025

Direct Tax

‘Huge, complex’ pillar two system encroaches on sovereignty: EY tax leader

Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut

Sam Sholli, July 14 2025

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

HMRC believes US companies underpaid £8.8bn in tax: accountancy group

The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year

Sam Sholli, July 14 2025