TPcases

In the case of the Coca-Cola Vietnam, which was decided in court on 27 November 2025, the tax authority found that Coca-Cola Vietnam’s related party transactions had not been priced ...

On 24 November 2025, HMRC released new operational guidance on the use of benchmarks, the narrowing of the arm’s-length range, and adjustments to the median. If the HMRC determines that ...

The OECD has released the contents of the 2025 update to the OECD Model Tax Convention. The main changes are as follows: Changes to Article 25 and its Commentary that ...

At this year’s event in Vienna, experts further explored emerging jurisprudence as transfer pricing cases continue to be litigated in a growing number of jurisdictions, emphasizing the importance of legal ...

The Australian Taxation Office’s draft Practical Compliance Guideline PCG 2025/D2 explains how the ATO assesses the tax risk of inbound cross-border related-party financing arrangements and the factors it takes into ...

On 23 May 2025, 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 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 ...

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 ...

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 ...