
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 outcomes in nearly every major tax jurisdiction, including the United States, EU Member States, India, the UAE, and others engaged…

A rebranding of the resale price method, cost plus method and berry ratio Whenever a new version of the OECD Transfer Pricing Guidelines is released, we do a complete read-through with the team. And we discover new things every time we read them, because our perspective on things changes as we continue to gain experience…