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Working Capital Adjustments in Transfer Pricing: Lessons from a Portuguese Court Case
A recent Portuguese arbitration case cuts to the heart of a question that comes up regularly in transfer pricing practice: when are working capital adjustments appropriate, and how far can a tax authority go in dismissing them? The case involves a limited-risk distributor, a TNMM benchmarking study, and a tax authority that accepted the comparable…
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Kenya’s Pineapple Case: What It Means for Transfer Pricing Globally
Our latest transfer pricing update takes us to Kenya, where a dispute involving the growing and selling of pineapples evolved into a fundamental debate about tested party selection, functional analysis, and the limits of contractual risk allocation under transfer pricing regulations. The case illustrates how tax authorities evaluate controlled transactions, assess transfer pricing risks, and…
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Best Practices for Effective Transfer Pricing Management in 2025
As international tax regulations tighten, managing Transfer Pricing (TP) documentation effectively is more critical than ever for multinational enterprises (MNEs). With increasing scrutiny from tax authorities, especially in major tax jurisdictions like the United States, companies must adopt clear strategies to align with OECD transfer pricing guidelines. Proper planning helps manage intercompany transactions, maintain transparency,…
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Kenya’s RPM vs TNMM Tribunal Ruling: Transfer Pricing Documentation Lessons for MNEs
In a pivotal decision, Kenya’s Tax Appeals Tribunal (TAT) recently ruled in the case of Avic International Beijing (EA) Ltd v. Commissioner of Domestic Taxes (TAT No. E786 of 2023). The dispute addressed whether the Resale Price Method (RPM) or the Transactional Net Margin Method (TNMM) was the appropriate transfer pricing method for controlled transactions…
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Introducing the Traditional Gross Margin Method (TGMM)
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…