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Transfer Pricing
OECD / IF documents
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Amount B report (February 2024)
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2010 Report on Attribution of Profits to Permanent Establishments
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Transfer Pricing Country Profiles & Implementation of the HTVI Approach
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Guidance on the Implementation of Country-by-Country Reporting (BEPS Action 13) (May 2024)
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IGF / OECD: Determining the Price of Minerals – A Transfer Pricing Framework (November 2023)
UN documents
Cases
2025
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Kamenitza (Bulgaria) (transfer pricing: trademark purchase) (in Bulgarian)
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Sofia Med (Bulgaria) (transfer pricing: service fees) (in Bulgarian)
2024
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Yazaki (Bulgaria) (transfer pricing: start-up losses for new projects) (in Bulgarian)
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Volkswagen (Argentina) (transfer pricing: extraordinary gain on loan forgiveness – impact on comparability) (in Spanish)
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Eaton (US) (transfer pricing: IRS succeeds in obtaining foreign employee performance evaluations)
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Siemens (Kenya) (transfer pricing: use of median in interquartile range)
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Engie (France) (transfer pricing; business segmentation) (in French)
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Samsung (India) (transfer pricing; characterisation as contract manufacturer vs. licensed manufacturer)
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Share-based awards TP case (Ireland) (transfer pricing treatment of share-based awards)
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BlackRock (UK) (deductibility of interest expense: transfer pricing and “unallowable purpose” rule)
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ABD Limited (South Africa) (transfer pricing: internal CUP)
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Singapore Telecom (Australia) (transfer pricing: determination of arm's length interest rate on related party vendor finance)
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Checkpoint (Kenya) (transfer pricing: can tax authorities make adjustment to median point in arm's length range?)
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Menarini Diagnostics (France) (can tax authorities use the median in the arm’s length range as the default for a transfer pricing adjustment?) (in French)
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Sumitomo Chemicals (France) (can tax authorities use the median in the arm’s length range as the default for a transfer pricing adjustment?) (in French)
2023
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Maersk (Denmark) (transfer pricing: discretionary assessment and determining price on aggregated basis) (in Danish)
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TP median case (Spain) (should transfer pricing adjustment be made to the median of the arm’s length range?) (in Spanish)
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Medtronic Ventor (Israel) (business restructuring) (in Hebrew)
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SAP Labs (India) (TP litigation: availability of appeals to High Court against ITAT’s decision)
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3M (US) (validity of “blocked income” transfer pricing regulation) (346 pages!)