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The case shows that legal relationships between parties bear significance and should be given sufficient weight in TP analyses, one local adviser says
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR
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Sponsored by Deloitte Transfer Pricing GlobalMo Malhotra, Ariel Krinshpun and Ockie Olivier evaluate how the OECD guidance on financial transactions will influence an increasingly convoluted transfer pricing environment. -
Sponsored by Deloitte Transfer Pricing GlobalDeloitte’s practitioners from across the globe report on four of the most prominent transfer pricing (TP) controversy cases from the recent past: Adecco (Denmark), Glencore (Australia), Cameco (Canada), and Philips (France).
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Sponsored by Deloitte Transfer Pricing GlobalJari Ahonen and Juan Ignacio de Molina discuss global examples and assess the practical impact of retroactively applying the OECD Transfer Pricing Guidelines.
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