Do Transfer Pricing Adjustments Trigger VAT? Transfer pricing adjustments made to correct intra-group prices do not automatically create a VAT liability as a separate supply of services. The CJEU confirmed this in Stellantis Portugal (C-603/24), ruling that a price change affects the taxable amount of the original transaction – not a new one. Introduction The
The OECD’s January 2026 Side-by-Side Safe Harbor limits the application of Pillar Two’s Income Inclusion Rule and Undertaxed Profits Rule to eligible US-parented multinationals. Where validly elected, top-up tax under those two rules is treated as zero. The Qualified Domestic Minimum Top-up Tax, however, continues to apply in every jurisdiction that has adopted it. Five
Brexit had an impact on various aspects of the UK economy and UK entities. One important aspect that was impacted is transfer pricing. Post Brexit, companies in the UK, or those that have trade in the UK, have to take more taxation matters with regard to their intragroup pricing. Pre-Brexit Transfer Pricing Framework Before Brexit,
Insights from the 3M Court Ruling A recent ruling by the Eighth Circuit Court of Appeals in 3M Company v. Commissioner may significantly influence how the IRS applies Section 482 to cross‑border transfer pricing adjustments. The case was an appeal of the US Tax Court’s decision in an audit matter between the IRS and 3M Company
Globalization has transformed worldwide human interactions, especially the way businesses approach their activities. Countries are now connected in new ways, and that connectivity has strengthened the economies of all the countries involved. With the increase in cross-border economic activity comes the need to set guidelines that will ensure an appropriate allocation of profits between the
Coca-Cola Case: The Central Company vs. The Tel Aviv District Tax Officer In recent years, rulings on transfer pricing have been accelerating globally as various tax authorities scrutinize the pricing policies of leading multinational groups. This trend is also present in Israel, highlighted by several judgments, including the Coca-Cola case. Recently, the Tel Aviv District
It depends. Some countries ask for the local file preparation if there are transactions, no matter the value of them, some ask only if the transaction or entity exceeds a set threshold. To understand if you need to have a local file documentation, you need to consider a few main aspects:
Global minimum tax is an OECD initiative introduced as a part of the BEPS program. The idea behind this initiative is to ensure that big multinational corporations are taxed at an effective tax rate of at least 15%. Most countries added this initiative to their local legislation. The entry into force date varies among the countries, for example, the EU has implemented the regulation from January 2024.
Amount B is a part of Pillar One from the OECD BEPS program. The purpose of Amount B is to act as a safe harbor for baseline marketing and distribution services.
Currently, the future of Amount B isn’t clear. As its implementation is optional, some countries including Germany and the Netherlands, already announced that they aren’t going to implement it.
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