Our Transfer Pricing News publication covers current topics and developments in transfer pricing.
The September edition of Transfer Pricing News explores recent transfer pricing developments across Africa, Asia and Europe. Key topics include the expansion of national transfer pricing regulations, updated documentation and reporting requirements, and court cases examining the application of the arm’s length principle to areas such as guarantees and financing arrangements involving financially distressed companies.
These developments demonstrate that transfer pricing compliance requires more than simply meeting technical requirements. Taxpayers must be able to demonstrate that related-party transactions have genuine commercial substance, are supported by up-to-date documentation and remain at arm’s length as business conditions, local guidance and case law evolve.
EMEA
- Italy: Supreme Court Rules Free Intragroup Guarantees May Be Arm’s Length When Commercially Justified
- Luxemburg: Administrative Court Upholds Interest Waiver in Distressed Financing Case
- Malta: Understanding When an Arrangement is “Materially Altered” for Transfer Pricing Purposes
- South-Africa: Domestic Arm’s Length Rule Proposed for Special Economic Zone Companies