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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MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure