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The risky side of transfer pricing

The revised OECD Transfer Pricing Guidelines (2017) include a detailed risk analysis framework to guide taxpayers and tax authorities on the allocation and assumption of risk under the arm's length principle. The purpose of this article is to review the current stance of tax authorities globally as to how they are intending to use this risk analysis framework in practice.

The impact of DEMPE

Before BEPS asking a TP practitioner what does DEMPE mean? might have elicited a strange response, but BEPS has changed all that. This article discusses DEMPE functions, what are they, which are important and what do they mean for a transfer pricing analysis.

Customs & TP – solutions for harmony

The rules governing customs duties and transfer pricing often don't align. Managing these inherent disconnections is complex, time consuming and challenging for businesses. This article discusses how to effectively manage these tensions and gain additional cross tax efficiencies and reduce risk/administrative burden.