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Dutch Guidance on the Cost-Plus Method: Key Lessons for Transfer Pricing
This week’s TP update takes us to the Netherlands. The Dutch tax authorities have issued practical guidance that’s worth a close read for anyone applying or defending a cost-plus model. In May 2025, the Dutch Tax Authorities’ Coordination Group Transfer (…)
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Indian Transfer Pricing Case Law Update: When “At-Cost” Pricing Prevails Over Mark-Ups
The first transfer pricing update of 2026 takes us to India, where a recent Mumbai Tribunal decision involving Shell offers important guidance for multinational enterprises navigating complex transfer pricing regulations. The case addressed a fundamental question relevant to many controlled transactions: can highly specialized technical services be priced at (…)
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Understanding the Arm’s Length Principle: The Foundation of Global Transfer Pricing
The arm’s length principle is the backbone of modern transfer pricing practices and one of the most important concepts in international tax law. It ensures that intercompany transactions between related entities—such as a parent company and its subsidiaries—are priced as if they were between unrelated parties operating under normal market conditions. This principle shapes tax (…)
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Czechia Transfer Pricing Update: Cost-plus Model Doesn’t Automatically Rescue Non-deductible Costs
Transfer Pricing in Czechia This week’s transfer pricing update heads to the Czech Republic, where a recent ruling by the Supreme Administrative Court of the Czech Republic (SAC) has clarified the limits of the cost plus method for intragroup services (…)
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Transfer Pricing & StockBased Compensation: Lessons from Ireland’s First TAC SBC Ruling
Ireland’s First Stock-Based Compensation Ruling by the TAC Equity incentives—stock options, restricted shares, or similar instruments—are a staple of compensation packages in multinational groups. But their accounting treatment sometimes clashes with transfer pricing logic, especially when subsidiaries recognize stock basec (…)
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PepsiCo vs Commissioner of Taxation: A Landmark Ruling on Transfer Pricing Compliance
A recent High Court of Australia decision has set a powerful precedent in the world of transfer pricing compliance. In the closely watched case of PepsiCo vs Commissioner of Taxation, the court sided with the multinational beverage giant in rejecting (…)
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Transfer Pricing Regulations: Defining Associated Enterprises under OECD Guidelines
For multinational corporations, identifying associated enterprises is essential to applying the arm’s length principle to intercompany transactions. This ensures prices align with those used between unrelated parties, helping to avoid double taxation and stay compliant with complex transfer pricing regulations (…)
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Common Challenges in Transfer Pricing Compliance
Navigating the world of transfer pricing compliance has become increasingly complex as tax jurisdictions globally continue tightening their transfer pricing rules. For multinational enterprises (MNEs), maintaining consistent pricing for intercompany transactions while complying with local tax laws, OECD frameworks, and (…)
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Why a Proactive Approach to Transfer Pricing Documentation Is Essential for Multinationals
Over the past decade, Reptune has conducted nearly a thousand introductory calls with prospective clients around the world. Across industries and markets, one question consistently arises: Should multinational enterprises adopt a proactive or reactive approach to transfer pricing documentation? While (…)
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Denmark’s 2025 Transfer Pricing Update: New Thresholds and Compliance Relief for Multinational Enterprises
Denmark continues to be a front-runner in global transfer pricing regulations, maintaining a structured compliance regime for multinational enterprises (MNEs) operating within or through the country. In June 2025, the Danish Parliament enacted important reforms to its transfer pricing documentation (…)