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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 (…)
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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 (…)
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Indian Transfer Pricing Case Law Update: When “At-Cost” Pricing Prevails Over Mark-Ups
The first transfer pricing update of 2026 takes us to India, where a recent Mumbai Tribunal decision involving Shell offers important guidance for multinational enterprises navigating complex transfer pricing regulations. The case addressed a fundamental question relevant to many controlled transactions: can highly specialized technical services be priced at (…)
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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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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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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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UK Transfer Pricing 2025: Key Compliance Updates, Risk Areas, and Dispute Resolution Trends
Transfer pricing remains a major priority for multinational enterprises (MNEs) operating in the United Kingdom. As corporate tax regulations tighten globally, HMRC has introduced sharper compliance measures focused on documentation, method selection, and risk profiling. In 2025, UK tax authorities (…)
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Iceland’s First Transfer Pricing Court Case: Key Lessons for Multinational Enterprises
In a landmark development, Iceland has delivered its first-ever court ruling on transfer pricing. It is important to use consistent transfer pricing methods. Companies should also conduct proactive risk assessments. This is especially true for multinational businesses involved in controlled (…)