TPcases

2 February 2026 the OECD has released a new 2026 version of the Manual on Effective Mutual Agreement Procedures (MEMAP). The Manual supports the broader focus of the BEPS Inclusive ...

18 December 2025 the Dutch tax authorities issued guidance for Tax and Customs Administration employees on the design and points of attention for the TP risk analysis. Mapping a taxpayer’s ...

Coca-Cola Vietnam's intragroup purchases of concentrate from related parties produced profits below the arm's length interquartile range established by the company's own benchmarking study. The Vietnamese tax authority applied the ...

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 ...

31 May 2025 the Dutch tax authorities issued transfer pricing guidance on guarantee fees. The memo addresses the assessment of the tax consequences of the provision of guarantees by a ...

31 May 2025 the Dutch tax authorities issued guidance on the application of the cost-plus method, and specifically the cost basis used. The cost-plus method is one of the methods ...