On 11 February 2020 the OECD released its first guidance on the transfer pricing aspects of financial transactions, constituting an important supplement and update to its 2017 Transfer Pricing Guidelines. The guidance is divided into five main sections, namely: Interaction with the guidance provided in section D.1 of the 2017 guidelines (accurate delineation …

I don’t know whether you’ve come across this Steve Jobs quote. I really like it: “I read a study that measured the efficiency of locomotion for various species on the planet. The condor used the least energy to move a kilometer. And, humans came in with a rather unimpressive showing, about a third of the way down the list. It was not too proud …

Changing behaviours is a key part of getting the results that you want, if you feel that things are off track. In the Sutton household, we can’t claim that threatening the ‘naughty step’ has been massively effective in changing the behaviour of our three-year-old, but sometimes it works. HMRC seems to have had more success with its …

This guest article was kindly contributed by Oliver Treidler and Tom-Eric Kunz, from TP&C GmbH, transfer pricing specialists based in Berlin, Germany. The OECD’s Base Erosion and Profit Shifting (BEPS) project has created uncertainty about various transfer pricing issues and has made an already complex issue even more complex. Now that the …

I had planned for this post to be about the Chinese Year of the Rat, and what it means if you were born in 1936, 1948, 1960, 1972, 1984 or 1996. But I’m writing this in China, having recently returned from a brief trip to the UK, and it doesn’t feel like the right time to try to entertain you with the story of the Chinese horoscope. Our thoughts …

Leading transfer pricing professionals agree that appropriate related party agreements, often referred to as ‘intercompany agreements’ or ‘ICAs’, are an intrinsic part of transfer pricing compliance. Nevertheless, many practitioners and corporates suffer from misconceptions about ICAs and how they need to work. In some cases, these misconceptions …