Transfer Pricing News

What You Should Know About the Discount Rate in A Transfer Pricing Valuation

The discount rate is one of the most important variables to consider when preparing a transfer pricing valuation. The OECD Transfer Pricing Guidelines define the discount rate as follows:

Transfer Pricing vs. Financial Reporting (Accounting) Valuations: What Are the Key Differences?

Valuations prepared for transfer pricing purposes serve different objectives from valuations for accounting purposes (e.g., IFRS, US GAAP or other accounting standards). While in theory transfer prici ...

Your tax controversy strategy can save a lot of interest!

TThe Dutch government is planning an explicit option to mitigate interest on underpaid tax when a Mutual Agreement Procedure (MAP) is conducted. However, this option still seems to be absent for bilat ...

CJEU: fees based on transfer pricing policy subject to VAT

The treatment of transfer pricing adjustments within VAT is not unambiguous and must be assessed on a case-by-case basis. There is now a concrete assessment framework for TNMM agreements.

Latest release EU Public CbCR implementation tracker

KPMG is excited to announce the release of its latest public CbCR Tracker, which offers a detailed and comprehensive overview of the public Country-by-Country Reporting (CbCR) regulations across the E ...

New US country-specific tariffs and the EU’s response

The United States has announced new country-specific reciprocal tariffs, with implementation set for 1 August 2025. These tariffs are being communicated through official letters from the White House t ...

The MAP team Annual Report 2024 published

The Dutch State Secretary for Finance published the Team Mutual Agreement Procedures (MAP team) Annual Report 2024 on May 26, 2025. This blog sets outs the highlights of this report.Taxpayers wan ...

Dutch Tax Rulings: 2024 Insights and Developments on APAs

The Dutch State Secretary for Finance provided the Parliament with the 2024 annual report on the ruling practice on May 22, 2025.  The 2024 report sheds light on the changes and developments in&n ...

Understanding the Dutch MAP Decree and its Application in Transfer Pricing Disputes

In cases of (potential) double taxation, don’t be put off by time-consuming and sometimes costly MAPs but act now to avoid unilateral double taxation. The unilateral option does not work in all cases, ...

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