SeemaSphere
Your gateway to global financial intelligence — featuring key developments in transfer pricing, tax law, and regulatory guidance.
Expore all reads
🇦🇷 Argentina’s Audit Earthquake: From Challenge to Settlement
Economic volatility means Argentine authorities routinely target large corporates for audit, with compliance focused on negotiation rather than drawn-out litigation. MNEs often preferred settling, seeking certainty in an uncertain legal and economic environment.
🪙 Zambia’s $13M Benchmark: Mopani Copper Set the New Standard
Resource extraction MNEs, including Mopani, were traditionally able to shift profits abroad using related-party trading companies. Zambia’s challenge marked a turning point, with support from the OECD to strengthen local capacity and implement real benchmarking in mining.
🎼 South Africa: Royalties Must Ring Arm’s-Length True
IP-rich sectors in South Africa have long relied on affiliate royalty arrangements, but local courts increasingly scrutinized the basis and benchmarking of such charges. This case featured a taxpayer defending arm’s-length royalty rates using deep market research amid revenue challenges based on rough averages.
🔄 SABIC India: Methodological Stability Wins the (Transfer Pricing) Day
Indian marketing support services and commodity groups, like SABIC, rely heavily on previously accepted benchmarking approaches. As scrutiny increased, authorities tried shifting methods without material changes to business facts. This case clarified that stable, justifiable methods are a compliance right.
Showing 111 to 120 of 114 articles
