A Portuguese arbitration court (Tribunal Arbitral) denied the tax authority’s transfer pricing challenge of a multinational’s cash pooling arrangement because its use of the comparable uncontrolled price (CUP) method was inappropriate. The case should alert Portuguese taxpayers to review the arm’s-length nature of their cash pooling arrangements.
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Luis Coronado suggests companies should embrace technology to assist with TP data reporting, as the ‘big four’ firm unveils a TP survey of over 1,000 professionals
KPMG Netherlands’ former head of assurance also received a permanent bar and $150,000 fine; in other news, asset management firm BlackRock lost a $13.5bn UK tax appeal