How Countries Stack Up in OECD’s 2024 APA Statistics Report
The OECD’s recently released 2024 Advance Pricing Agreement and Mutual Agreement Procedure statistics shine a light on the effectiveness of countries APA and MAP programs.
Tax Management International
Latest Tax Journals
Transfer Pricing Landscape Shifts Amid IRS Changes and Tariffs
The US transfer pricing landscape has been volatile in 2025 and promises to remain at the forefront of multinationals’ tax strategies heading into 2026.
China Manufacturing Involution Is Redefining Transfer Pricing
China’s domestic market involution is forcing multinational corporations to fundamentally rethink their transfer pricing strategies, as intense local competition erodes traditional benchmarks for profitability and value.
CJEU Clarifies VAT Rules for Toolings Activities: Brose Prievidza
The CJEU clarifies the VAT treatment for manufacturers’ tooling purchases from subcontractors.
Courts Play Key Role As Transfer Pricing Disputes Escalate
Transfer pricing is no longer a technical exercise but a governance issue involving decisions about value chains, intellectual property ownership, and distributor characterization that must withstand courtroom-level interrogation.
How Will Generative AI Affect Value Chains and Transfer Pricing?
As GenAI continues to evolve, companies should monitor potential changes in their business models and value chains to understand the impact on existing transfer pricing structures and policies.
South African Tax Rules Murky on Debt, Preference Share Funding
Technical analysis of South Africa’s evolving tax treatment of debt and preference share funding instruments is presented with a focus on the March 2025 Tax Court ruling on raising fees and 2025 Tax Laws Amendment Bill relating to hybrid equity instruments.
How Does OBBBA Affect Canada-US Individuals Tax Comparisons?
Individual tax laws in Canada and America are compared.
How Do US-Asia Trade Agreements Affect DSTs, FDDEI and VAT?
The US recently announced trade agreements and trade framework agreements with Cambodia, Malaysia, Thailand, and Vietnam that have important implications for DSTs, the US’s FDDEI regime, and VAT.
Safe Harbors: Is the Arm’s Length Principle Losing Its Grip?
While the full arm’s length principle is reserved for complex, high-stakes cases, safe harbors can be deployed for routine fact patterns.
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