SeemaSphere
Your gateway to global financial intelligence — featuring key developments in transfer pricing, tax law, and regulatory guidance.
Expore all reads
📊 Outlier, Not Out-of-Luck: Denmark’s Supreme Court Picks Proof Over Percentile
In Denmark’s competitive tech and electronics sector, slim margins and shifting business models are normal. EET Group, an electronics distributor, reported affiliate profits outside Denmark’s statistical interquartile range (IQR), raising red flags in a jurisdiction known for strict numerical benchmarking.
📡 Vodafone’s $2.2B Indian Indirect Transfer Stunner
Telecom MNEs like Vodafone operate across complex group structures, especially in fast-growing markets like India. The company executed a major offshore M\&A deal, acquiring control of an Indian subsidiary through foreign holding companies. At the time, Indian tax law’s reach into such “indirect” asset transfers was ambiguous.
🔁 Audit Whiplash: SABIC India’s Benchmarking Win
India’s manufacturing sector hosts many foreign MNEs, like SABIC, that provide marketing and support services to overseas group entities. Transfer pricing enforcement in India is robust, and authorities sometimes try to change accepted benchmarking to boost assessments.
⛏️ Mining for Value: Australia’s A$1B Marketing Hub Settlement
Australia’s prosperous mining sector heavily features resource giants like Rio Tinto, which established a Singapore marketing hub for selling locally mined ore. The hub centralized sales, marketing, and logistics for Asian and global buyers—a legitimate business model, but one with TP challenges on profit allocation.
⚖️ 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.
Showing 101 to 110 of 114 articles
