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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…