TP Tax Articles
In our Insights section, you can explore a wide range of articles and publications on key transfer pricing matters. We offer our expert perspectives on the most pressing issues, provide simple explanations to complex transfer pricing matters, and much more.
Transfer Pricing Fundamentals
Transfer Pricing Methods: The Five OECD-Approved Approaches and the Sixth Method
The OECD recognizes five transfer pricing methods for pricing intercompany transactions: CUP, RPM, CPM, TNMM,
Getting Transfer Pricing Right in Cross-Border Operations
What Tax Authorities Focus On – and How Businesses Can Reduce Exposure When a business
Key Issues and Opportunities in Transfer Pricing
Transfer pricing is an important global issue for companies. It applies to transactions between related
Arm’s Length Principle
The arm’s length principle is an important pillar of the transfer pricing regulations and policies,
Transfer Pricing Explained
Over the past couple of years, transfer pricing (TP) has become a topic of discussion
Documentation and Compliance
Country by Country Reporting: A Practical Guide for Multinational Enterprises
Country by country reporting (CbCR) is an annual filing obligation for large multinational enterprises (MNEs)
Transfer Pricing Documentation
One of the many aspects of Transfer pricing (TP) compliance is adhering to the documentation
Methods and Benchmarking
The Profit Split Method in Transfer Pricing
The Profit Split Method (PSM) is one of five OECD-recognized transfer pricing methods. It identifies
The Transactional Net Margin Method: How TNMM Works in Transfer Pricing
The Transactional Net Margin Method (TNMM) benchmarks a tested party’s net profit margin against comparable
Resale Price Method in Transfer Pricing: A Practical Guide
The resale price method (RPM) is one of three traditional transaction methods under the OECD
The Comparable Uncontrolled Price (CUP) Method in Transfer Pricing
The Cost-Plus Method in Transfer Pricing: What It Is and When It Actually Applies What
Cost Plus Method in Transfer Pricing
Cost Plus Method in Transfer Pricing: When and How to Apply It The Cost Plus
Economic Recession and Transfer Pricing: What to Consider
Recessions affect the economy in many ways, directly influencing consumer demand, global supply chains, and,
Intercompany Transactions
Transfer Pricing and Customs Valuation
Transfer pricing and customs valuation do not test related-party pricing in the same way. Transfer
When a Distributor Loses Money: What Transfer Pricing Rules Actually Say
Under both the OECD Transfer Pricing Guidelines and US regulations, a related-party distributor can be
Low Value-Adding Services in Transfer Pricing: A Practical Guide
Low value-adding intra-group services (LVAS) are routine support functions – such as HR, IT, and
Transfer Pricing for Intercompany Loans
Many corporates consider intercompany loans as sophisticated financial instruments that can be used to finance
Audits, Disputes and Global Developments
Transfer Pricing Adjustments and VAT: What the Stellantis Portugal Ruling Means for Multinationals
Do Transfer Pricing Adjustments Trigger VAT? Transfer pricing adjustments made to correct intra-group prices do
Pillar Two Relief for US Multinationals: The 2026 OECD Side-by-Side Safe Harbor
The OECD’s January 2026 Side-by-Side Safe Harbor limits the application of Pillar Two’s Income Inclusion
Brexit Impact on UK Transfer Pricing
Brexit had an impact on various aspects of the UK economy and UK entities. One
A Shift in the IRS’s Powers to Make Transfer Pricing Adjustments?
Insights from the 3M Court Ruling A recent ruling by the Eighth Circuit Court of
Base Erosion and Profit Shifting Action Plan (BEPS)
Globalization has transformed worldwide human interactions, especially the way businesses approach their activities. Countries are
Transfer Pricing – Another Victory for Tax Authority in Charging Tax on Royalties
Coca-Cola Case: The Central Company vs. The Tel Aviv District Tax Officer In recent years,