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Your gateway to global financial intelligence — featuring key developments in transfer pricing, tax law, and regulatory guidance.
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⚖️ Dow Canada: Getting the Right Court is Everything
Global chemical leaders like Dow have layered supply chains and financing across geographies. In Canada, Dow sought to challenge a downward TP adjustment, prompting debate over whether the Tax Court or Federal Court had jurisdiction for such administrative matters.
💸 Czech LIBOR Letdown: RR Donnelley Beats the “Loan” Analogy
In the Czech industrial sector, RR Donnelley’s local operations made frequent intercompany purchases from group entities. Authorities, amid a regional clampdown on profit shifting, began treating these payment terms as loans, applying LIBOR interest benchmarks—a trend growing across Central and Eastern Europe pre-OECD BEPS financial reforms.
🛢️ Malaysia’s Margin Battle: Sandakan Edible Oils Defends the Safe Harbor
Malaysia’s export industries often rely on transfer pricing safe harbors through arms-length ranges (IQR). Sandakan Edible Oils, like many regional firms, set its reported profits within this range, even if not always at the median. Before BEPS/TP refinement, tax authorities were increasingly tempted to adjust results toward maximum revenue using the median alone.
📂 Samsung’s Documentation Masterclass: How Audit-Ready Beats Aggressive Benchmarks
The Korean electronics sector thrives on cross-border supply chains, with Samsung routinely exporting components to group affiliates. As TP audits grew more aggressive regionally, documentation quality became the decisive factor—sometimes more so than statistical benchmarks.
💳 Lending Clarity: Watsons Proves Arm’s Length is Deliverable
Retail MNEs need working capital, often sourced via intercompany loans. Watsons structured group financing based on actual third-party bank offers, defending this as market-standard. Malaysian revenue authorities, fearing base erosion, frequently challenged group loan rates as too low before recent financial transaction guidelines.
📉 Colombia’s Loss Makers: The End of “Profit-Only” Benchmarks
Colombia’s markets, like many in Latin America, face periodic cycles and downturns. Authorities had often excluded loss-making comparables when benchmarking, believing only profitable entities reflected true arm’s-length pricing. This practice was increasingly at odds with OECD BEPS guidance recognizing the legitimacy of business cycles.
🇦🇷 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.
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