July 25 2023
Transfer pricing disputes have consistently been the most pressing issues for multinational groups in the post-BEPS era, as countries look to gain a “fairer” share of global profits by challenging their intragroup pricing arrangements. At the same time, the updated OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations have provided countries with more tools that can be applied to ensure intra-group transfer pricing arrangements conform with the arm’s length principle. How are these concerns and developments reflected in recent transfer pricing cases? What can we learn from these cases that would help better understand the transfer pricing risks and how to manage them?
Block 1: Post-BEPS transfer pricing landscape
Block 2: Transfer pricing cases
Block 3: Practical impact of recent transfer pricing cases
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