TPcases

Large multinational groups with a calendar financial year have until 31 December 2026 to publish their first EU public country-by-country report (public CbCR), covering financial year 2025. With three months ...

The 2026 WU Transfer Pricing Symposium, which will take place on 12 and 13 October in Vienna, Austria, offers a forum to examine how courts are shaping the technical and ...

Coca-Cola Vietnam's intragroup purchases of concentrate from related parties produced profits below the arm's length interquartile range established by the company's own benchmarking study. The Vietnamese tax authority applied the ...

On June 1, 2026, the OECD released a document proposing revisions to the existing provisions in Chapter VII of the OECD Transfer Pricing Guidelines, which provide guidance on intra-group services ...

2 February 2026 the OECD has released a new 2026 version of the Manual on Effective Mutual Agreement Procedures (MEMAP). The Manual supports the broader focus of the BEPS Inclusive ...

Coca-Cola Vietnam's intragroup purchases of concentrate from related parties produced profits below the arm's length interquartile range established by the company's own benchmarking study. The Vietnamese tax authority applied the ...

On 24 November 2025, HMRC released new operational guidance on the use of benchmarks, the narrowing of the arm’s-length range, and adjustments to the median. If the HMRC determines that ...

The OECD has released the contents of the 2025 update to the OECD Model Tax Convention. The main changes are as follows: Changes to Article 25 and its Commentary that ...

The Australian Taxation Office’s draft Practical Compliance Guideline PCG 2025/D2 explains how the ATO assesses the tax risk of inbound cross-border related-party financing arrangements and the factors it takes into ...