Will Pillar One’s new taxing right diminish the iconic status of the arm's length standard, and if so, with what long-term impact on tax treaties? What are the implications of Pillar One’s reliance on ...
In European Commission v. Ireland, C-465/20 P, the EU’s highest court has confirmed that member states enjoy broad autonomy to design their transfer pricing regimes however they see fit — except when ...
In this installment of In the Pages, Tax Notes International contributing editor Robert Goulder sits down with Bill Parks, retired finance professor and founder of 100 percent employee-owned NRS Inc., ...
As businesses engage in cross-border transactions with related parties, transfer pricing adjustments become essential to ensure compliance with the arm’s length principle. These adjustments help align ...