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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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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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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 (…)
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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 (…)