Transfer Pricing Case Laws

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TP Newsletter

Common Errors made in Country-by-Country reports

On 23 May 2024, the OECD issued guidance on common errors made by multinational enterprise (MNE) groups when preparing their country-by-country (CbC) reports. These reports contain valuable information on the ...

Germany’s new record keeping obligation – Transaction Matrix

Germany has issued guidance on a recent addition to German taxpayers’ transfer pricing documentation obligations. The transaction matrix now required under Section 90 (3) sentence 2 no. 1 AO is ...

Germany – Updated Administrative Principles on Transfer Pricing 2024

12 December 2024, the German Federal Ministry of Finance published updated administrative principles on transfer pricing 2024 (VWG VP 2024). The updates mainly concern the chapter on financial transactions, where ...

Inland Revenue of New Zealand – Multinational Enterprises Compliance Focus 2024

1 October 2024, the New Zealand Inland Revenue published a new 2024 edition of its Multinational Enterprises Compliance Focus. According to the publication (page 23), the provision of risk indicators ...

Peru – SUNAT guidance on pricing of intra-group services and application of the benefit test

9 September 2024, the Peruvian tax authority – SUNAT – issued guidance on the qualification of services, transfer pricing methods for services and the application of the “benefit test”. Click ...

Statement from the Inland Revenue of New Zealand on Withholding Taxes arising from Transfer Pricing Arrangements

30 August 2024 the Inland Revenue of New Zealand issued Commissioner’s Statement CS 24/02. The Statement that sets out the Commissioner’s position in relation to the withholding tax obligations that may ...

ATO seeks special leave to appeal the Full Federal Court’s PepsiCo-decision to the High Court

The Australian Tax Office (ATO) has applied for special leave to appeal to the High Court of Australia against the Full Federal Court’s decision in PepsiCo, Inc. v Commissioner of ...

OECD releases lists of qualifying and covered jurisdictions under Amount B

On 17 June 2024, additional guidance and lists of qualifying and coverred jurisdictions under Amount B was released by the OECD. The additional guidance includes: The definitions of qualifying jurisdictions within ...

Germany adds new TP-Provisions to the Foreign Tax Act (Außensteuergesetz)

On 27 March 2024, new paragraphs (3d) and (3e) were added to the German Foreign Tax Act (Außensteuergesetz – AStG) regarding intragroup financing. Paragraph (3d) concerns the determination of arm’s ...

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