Ryan Finley explains why the IRS’s recent advice memorandum on periodic adjustments may signal a significant change in ...

A wide spectrum of tools exists to support the intercompany transfer pricing process. These can be broadly categorised into policy management, policy implementation, and compliance tools. Many ...

In today’s globalised economy, intangible assets play a critical role in driving business value, particularly for ...

Transfer pricing refers to the actual price charged in transactions between related entities within the same multinational ...

Transfer pricing concerns the prices charged between associated enterprises established in different tax jurisdictions for their intercompany transactions. The relationship threshold for transfer ...

Rationalisation of transfer pricing provisions for carrying out multi-year Arm’s Length Price determination 92CA. (1) Where any person, being the assessee, has entered into an international ...

From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue ...

Transfer pricing rules are designed to ensure that income from international transactions or certain domestic transactions is determined on the basis of an “arm’s length price” (ALP). This means that ...

Budget 2025 proposes a block assessment mechanism for transfer pricing to reduce compliance burdens. The new approach allows ...

Kirsty McMillan, tax partner at Forvis Mazars in Singapore, focuses on helping clients with their expansion, restructuring ...

The UK’s tax authority in 2023-2024 settled transfer pricing cases the quickest it has in four years. His Majesty’s Revenue and Customs settled inquiries in 33.1 months on average in 2023-2024, a ...