-
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 (…)
-
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 (…)
-
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 (…)
-
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 (…)
-
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 (…)
-
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 (…)
-
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 (…)
-
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 (…)