Transfer Pricing
Stay ahead of the complex world of intercompany transactions. Our Transfer Pricing category delivers the latest news on OECD Amount B, BEPS Action 13, and evolving documentation requirements across global jurisdictions.
We provide expert analysis on benchmarking, arm’s length principle application, and Master File/Local File compliance trends in EMEA, APAC, and LATAM. Whether you are navigating audit risks or optimizing global value chains, TaxSpoc offers the practical knowledge needed to manage transfer pricing controversy and ensure international tax transparency.
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THIS WEEK
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Operational Transfer Pricing: Profitability Monitoring and Pricing Adjustments
Operational Transfer Pricing requires more than setting transfer prices at the beginning of the year. Multinational enterprises need to continuously monitor actual profitability, identify deviations from target returns and determine whether pricing adjustments are required. This article examines the practical monitoring cycle, from monthly and quarterly profitability reviews to interim pricing adjustments and final year-end…
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ECJ Clarifies VAT Treatment of Intra-Group Transfer Pricing Adjustments in Stellantis Portugal (C-603/24)
On 13 May 2026, the Court of Justice of the European Union delivered its judgment in Stellantis Portugal (C-603/24),…
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Canada’s New Transfer Pricing Framework: How Bill C-15 Changes CRA Audit Powers and Compliance Expectations
Canada has entered a new phase in transfer pricing enforcement following the adoption of Bill C-15. The legislative amendments…
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The Quiet Diplomacy of Taxes: How the Mutual Agreement Procedure Prevents Double Taxation
In the complex world of international taxation, disputes between governments are almost inevitable. When companies operate across borders, differences…
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French Finance Act 2026: Key Corporate Tax Changes, Pillar Two Updates and New Levies
The French Finance Act for 2026 introduces a number of targeted tax measures affecting large companies, multinational groups, holding…
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Key Tax & Regulatory Developments Mexico (Mar 1–7, 2026. Part 1)
The following summary highlights several important tax, trade, and regulatory developments in Mexico that occurred during the first week…
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UK Launches Open Consultation on Transfer Pricing, Permanent Establishment and Diverted Profits Tax
Stakeholders are invited to review the draft legislation and submit their feedback by 11:59pm on 7 July 2025. The…
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Turkey Decides Not to Implement OECD’s Amount B for Now
Amount B will not be applied to transactions involving distributors, sales agents, and brokers operating in Turkey
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Council Reaches Political Agreement on DAC9
MNEs will be required to submit their first top-up tax information return by 30 June 2026, tax authorities will…
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Pillar One Amount B: Key Update on Marketing and Distribution Activities
Jurisdictions can adopt OECD’s Latest Guidelines on the Amount B approach for relevant transactions starting from fiscal years commencing…