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UK Transfer Pricing Update: HMRC Adopts a “Meet-in-the-Middle” Approach to Transfer Pricing Ranges
In this week’s transfer pricing update, we turn to the United Kingdom, where HM Revenue & Customs (HMRC)—the UK’s primary tax authority—has released guidance clarifying how it intends to apply the arm’s-length range when reviewing controlled transactions. Under the arm’s (…)
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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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Transfer Pricing in Argentina: Risks of a Static Tested-Party Approach vs. the OECD Dynamic Model
Argentina diverges notably from the OECD’s recommended transfer pricing framework by enshrining a static tested‑party approach for intercompany pricing—mandating that the local Argentine entity always be the tested party. This stance contrasts sharply with the OECD’s dynamic approach, which aligns (…)
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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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Choosing the Right Transfer Pricing Method: A Practical Guide for Multinational Enterprises
Transfer pricing remains one of the most scrutinized areas of corporate tax compliance for multinational enterprises (MNEs). Selecting the right transfer pricing method isn’t just about meeting regulatory requirements—it’s about aligning your pricing model with the commercial reality of your (…)
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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 (…)
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When Is a Cost Really a Cost? Lessons from the Czech Court on Transfer Pricing and Inventory Pass-Through
Transfer Pricing Dilemma: Cost Exclusion and TP Documentation Challenges It’s a classic transfer pricing dilemma: when using a cost-based method, can a company exclude some costs from the markup because they don’t add value? This scenario frequently arises in controlled (…)
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Yara vs Dutch Tax Authorities: A High-Stakes Transfer Pricing Showdown in the Netherlands
This blog post takes us to Reptune’s home country—the Netherlands—where the Dutch Supreme Court recently delivered its final ruling in the long-standing dispute between fertilizer giant Yara and the Dutch Tax Authorities (DTA). At the heart of the case? The (…)