Ugly cousins and Rube Goldberg machines in Transfer Pricing
Do you have any ‘ugly cousins’ in your group legal structure? I hasten to say that none of my actual cousins are ugly. But in the legal world of multinational groups, ‘ugly cousins’ are common. Coca-Cola is a prime example. The Court said the group’s intercompany agreements were ‘outmoded’ and ‘inconsistent with their actual behavior’. …