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Simple World Map Author: Al MacDonald Editor: Fritz Lekschas License: CC BY-SA 3.0 ID: ISO 3166-1 or "_[a-zA-Z]" if an ISO code is not available
714 articles

Dr. Daniel N Erasmus to Address Key Transfer Pricing Challenges at Africa 2024 Conference

Dr. Daniel N Erasmus, a leading expert in international tax law and transfer pricing, will be a key speaker at the upcoming Online Transfer…

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Belgium

Exchange of information on reportable cross-border tax arrangements: CJEU Judgment in Case…

The judgment in the case C-623/22, issued by the Court of Justice of the European Union (CJEU) on July 29, 2024, primarily addressed the…

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Optimised Transfer Pricing Compliance: UNs End-to-End Toolkit

The Transfer Pricing Compliance Assurance – An End-to-End Toolkit developed by the United Nations Subcommittee on Transfer Pricing is a…

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Mauritius

Avago Technologies Trading Ltd v/s Director General, MRA Judgment

The Assessment Review Committee (ARC) ruled in favor of the Mauritius Revenue Authority (MRA) in the case of Avago Technologies Trading Ltd…

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The Importance of Organizational Structure and Business Overview in Transfer Pricing…

The importance of organizational structure and business overview in transfer pricing documentation cannot be overstated. These elements…

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Transfer Pricing Policies and Methodologies in Transfer Pricing Documentation

Transfer pricing policies and methodologies are critical components of transfer pricing documentation, which is essential for multinational…

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Importance of Financial Data and Calculations in Transfer Pricing Documentation

The importance of financial data and calculations in transfer pricing documentation cannot be overstated. Accurate financial information…

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Argentina

Understanding Intra-Group Losses in Transfer Pricing: Key Insights from Recent Cases

Intra-group losses in transfer pricing have become a focal point of legal scrutiny and regulatory enforcement. The recent cases of Dart…

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The Resale Price Method in Major Transfer Pricing Cases

Transfer pricing continues to be a critical issue for multinational corporations. The resale price method (RPM) plays a significant role in…

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Intercompany Agreements and Contracts in Transfer Pricing Documentation

Intercompany agreements and contracts are critical elements in transfer pricing, ensuring that transactions between related entities within…

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Canada

Dow Chemical Canada ULC v. The King: Tax Court Jurisdiction in Transfer Pricing Disputes

The Dow Chemical Canada case underscores the complex interplay between tax law, administrative discretion, and jurisdictional issues in…

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Australia

PepsiCo v Australia: Implications for Royalty Withholding Tax and Diverted Profits Tax

The Federal Court of Australia’s judgment in PepsiCo, Inc v Commissioner of Taxation provides critical insights into the characterization…

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Malaysia

Keysight Technologies v. Malaysia: Implications for Transfer Pricing and Tax Compliance

The Keysight Technologies Malaysia case underscores the complexities of transfer pricing and tax compliance. By understanding the court’s…

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Denmark

Understanding Non-Recognition in Transfer Pricing

Explore non-recognition in transfer pricing through landmark cases from Malaysia, Luxembourg, and Denmark. Expert analysis by Prof. Dr.…

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Malaysia

Malaysia Transfer Pricing Case: Watsons Personal Care Stores vs Tax Authorities

Summary of Malaysian transfer pricing case of Watsons Personal Care Stores vs tax authorities, its implications for multinationals, and key…

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Understanding the Profit Split Method (PSM) in Transfer Pricing

The Profit Split Method in Transfer Pricing is a crucial approach used to ensure that transactions between related companies are conducted…

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Understanding the Transactional Net Margin Method (TNMM) in Transfer Pricing

The Transactional Net Margin Method (TNMM) is a pivotal tool in transfer pricing, used to ensure that transactions between associated…

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The Cost Plus Method in Transfer Pricing

The Cost Plus Method is a widely used approach in transfer pricing for determining arm’s length prices between related entities. This…

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Understanding the Comparable Uncontrolled Price (CUP) Method in Transfer Pricing

The Comparable Uncontrolled Price (CUP) Method is one of the primary transfer pricing methods used to determine arm’s length prices for…

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Denmark

Danish Supreme Court Upholds Transfer Pricing Adjustment in Maersk Oil Case

Summary of the Danish Supreme Court’s landmark ruling on transfer pricing in the Maersk Oil case, with implications for multinationals and…

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Understanding the Resale Price Method in Transfer Pricing

The Resale Price Method in Transfer Pricing is a fundamental approach used by multinational enterprises (MNEs) to ensure compliance with…

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Luxembourg

Luxembourg vs “LLC AB”: Luxembourg Court Upholds Debt Classification of Interest-Free Loan in…

Luxembourg court rules interest-free loan qualifies as debt, allowing notional interest deduction in landmark transfer pricing case with…

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The Arm’s Length Principle in Transfer Pricing

Learn about the Arm’s Length Principle in Transfer Pricing, its importance, methods, and why consulting experts like TRM is crucial for…

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Understanding the Burden of Proof in Transfer Pricing: Insights from Recent Court Cases

Explore the critical role of the burden of proof in transfer pricing through analysis of recent Dutch, Czech, and Italian court cases.

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