Danish Master FilesDanish Master Files
Background For the taxable year 2025, the Ordinance on Documentation of the Pricing of Controlled Transactions (“TP Documentation Ordinance”) from{...}
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Intercompany Agreements for TPIntercompany Agreements for TP
Background Intercompany agreements (“ICAs”) are written legal contracts covering specified intra-group transactions within multinational groups. They especially determine the transfer{...}
German TP Documentation – Transaction MatrixGerman TP Documentation – Transaction Matrix
A couple of months ago, Germany amended its transfer pricing (“TP”) legislation. Article 90 of the Foreign Tax Act now{...}
Weakening of Swiss Safe-Harbor ProtectionWeakening of Swiss Safe-Harbor Protection
On 11 Juli 2024, the Federal Supreme Court of Switzerland (“FSCS”) ruled on the applicability of the Swiss safe harbor{...}
Swiss Administrative Guidance on TPSwiss Administrative Guidance on TP
On 23 January, the Swiss Federal Tax Administration published a report on transfer pricing on its website. It reflects the{...}
New Brazilian Transfer Pricing RegulationsNew Brazilian Transfer Pricing Regulations
Over the course of this year, Brazil revised its transfer pricing (“TP”) regulations fundamentally. The country promulgated a new legal{...}
Improved Approach to Company Size PremiumsImproved Approach to Company Size Premiums
In an article in The Value Examiner, David H. Goodman addresses company-specific risk. Risk-premiums compensating for company-size have a long{...}
Current Survey on the Cost-Plus Method in the DACH-RegionCurrent Survey on the Cost-Plus Method in the DACH-Region
Dr. Sven-Eric Bärsch, Dr. Xaver Ditz, and Dr. Sven Kluge from Flick Gocke Schaumburg together with Dr. Ralf Eberenz and{...}
New OECD Country Profiles made AvailableNew OECD Country Profiles made Available
On 9 June, the OECD published four new Transfer Pricing Country Profiles (“Country Profiles”). They cover Egypt, Liberia, Saudi Arabia,{...}
New Challenging TP Requirements in DenmarkNew Challenging TP Requirements in Denmark
In line with international standards, Danish transfer pricing (“TP”) legislation requires calculating taxable income under the arm’s-length principle. This means{...}
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