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Transfer pricing method selection remains one of the most contested areas in cross‑border tax. Although the OECD Transfer Pricing Guidelines (TPG) emphasise the “most appropriate method to the circumstances of the case” standard rather than a strict hierarchy, tax authorities worldwide are increasingly assertive in pushing for traditional transaction methods — particularly the Comparable Uncontrolled…
In the latest episode of the LCN podcast, we had the privilege of hosting Candy Liu, Strategic Global Account Lead at Microsoft. Candy advises some of Microsoft’s 200 global strategic accounts, which means her role gives her a unique vantage point on what AI adoption really looks like inside the world’s largest enterprises. This blog…
At a recent LCN roundtable, one question dominated the transfer pricing conversation: how to prioritise action to achieve tax and transfer pricing audit readiness – given the amounts at stake, and the range of inter-related factors? To help answer that, we introduced the Transfer Pricing Health Wheel, a practical self-assessment tool designed to spotlight strengths…
In a recent webinar, LCN hosted Donal O’Connell, former Director of IP at Nokia and a highly experienced practitioner in global IP management, for a deep dive into one of the most persistent blind spots in transfer pricing: how to identify intangibles in the first place. Transfer pricing professionals are well-versed in DEMPE analysis. The…
Africa’s transfer pricing landscape has changed more in the past five years than in the previous twenty. That was the clear message from LCN’s recent webinar with Cabrini McCarrick and Rajnish Singh of Regan Van Rooy, international tax advisers based in South Africa, Mauritius, Ireland and the UK. For many multinationals, Africa still feels like…
Transfer pricing is rarely the sole driver of intercompany agreements (ICAs) or group legal structures. It is one of several critical factors that must be weighed. ICAs are the factual anchor for a group’s dealings across tax, customs, regulatory, and governance domains, as the recent Tauritus case demonstrates in the context of VAT and customs…
Most multinational groups operate with complex webs of legal entities, cross-border roles, intercompany flows, and regulatory obligations, but very few have a single, coherent framework that explains how all of this is supposed to work. That gap is increasingly becoming a real source of tax, governance and operational risk. Tariff escalation, diverging U.S.–EU approaches to…
In a landmark ruling that reshapes the boundaries of U.S. transfer pricing enforcement, the Eighth Circuit Court of Appeals has sided with 3M in its long-running dispute with the IRS over “blocked income.” The court reversed a $24 million adjustment, holding that U.S. tax law cannot compel recognition of royalty income that a taxpayer is…
A key function of intercompany agreements is to specify the price for the relevant transactions. In general, this requires that the actual amount of the price to be charged is either ascertained or is ascertainable by reference to objective criteria. It is not enough for the parties to agree that the price shall be equal…
Commissionaire structures are a distinctive feature of civil law jurisdictions and frequently appear in the operating models of multinational groups. While the legal concept may seem arcane, its implications for transfer pricing, permanent establishment risks, and intercompany agreement design are far-reaching. At its core, a commissionaire arrangement allows a person or entity to sell goods…