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Reproduced with permission. Published 10.5.26 Author Bios: Ami Goldenstein is the founder of TP Right. He is a transfer pricing and international tax professional with over 25 years of experience, dedicated to optimizing global transfer pricing and tax strategies that drive efficiency, compliance, and risk mitigation. He has deep expertise in operational transfer pricing, audits and controversy, intercompany financial transactions, valuations, and intercompany agreements, lev

Reproduced with permission. Published 9.8.26 Can DEMPE Contributions Be Measured With Greater Consistency? Author Bios: Ami Goldenstein is a Transfer Pricing and International Tax professional with over 25 years of experience, dedicated to optimizing global transfer pricing and tax strategies that drive efficiency, compliance, and risk mitigation. With deep expertise in operational transfer pricing, audits and controversy, intercompany financial transactions, valuations and I

Few transfer pricing cases have attracted as much attention as the Coca-Cola litigation. More than a decade after the dispute began, the case continues to shape discussions around intangible ownership, transfer pricing methodologies, and the importance of aligning legal arrangements with economic outcomes. The financial stakes are extraordinary. Following the Tax Court's decision, Coca-Cola has already paid approximately $6 billion in taxes and interest while pursuing its app

The OECD recently released a Public Consultation Document proposing revisions to Chapter VII of the OECD Transfer Pricing Guidelines, addressing the treatment of intra-group services. While the consultation is not intended to fundamentally change the existing transfer pricing framework, it provides important clarifications, additional examples, and practical guidance that may influence how taxpayers and tax authorities evaluate service transactions going forward. Renewed Focu

The OECD’s recently released Global Minimum Tax Implementation Toolkit provides one of the clearest operational roadmaps to date for how tax administrations can implement and administer the Pillar Two Global Minimum Tax (GMT) framework. The Toolkit reflects lessons learned from the “Amsterdam Dialogue,” a collaborative initiative launched in 2024 involving nearly 70 tax administrations, business representatives, academics, and other stakeholders focused on practical implement

The Importance of Pillar 2 in Today's Tax Landscape Pillar 2 is now in execution mode. The first GloBE Information Returns are due soon. Tax teams must transition from modeling to real data, systems, and deadlines. The OECD’s 2026 Side-by-Side (SBS) Package does not change Pillar 2’s goal of a 15% minimum tax. However, it alters how groups operate by introducing practical “safe harbours” and transition relief. Simplified ETR Safe Harbour (SESH) What is SESH? SESH is designed

The OECD’s Amount B framework represents a significant shift in the application of transfer pricing to baseline marketing and distribution activities. Originally released on 19 February 2024, and consolidated in the 2025 OECD report, Amount B forms part of Pillar One and aims to simplify pricing, reduce disputes, and enhance tax certainty, particularly for low-capacity jurisdictions. The guidance has now been formally incorporated into the OECD Transfer Pricing Guidelines as

The OECD’s 2026 update to the Manual on Effective Mutual Agreement Procedures (MEMAP) provides a more practical and structured view of how the Mutual Agreement Procedure (MAP) should operate in practice. While the guidance is not binding, it introduces a set of best practices aimed at improving efficiency, transparency, and timeliness in resolving cross-border tax disputes. Access and Timing: A Narrow but Critical Window Taxpayers generally have up to three years from the fi

After more than 20 years working mostly in-house in transfer pricing, one recurring theme has become very clear to me: operational transfer pricing is still largely driven by spreadsheets. At the core of operational transfer pricing is the need to test whether controlled transactions meet the arm’s length standard. In practice, this typically involves building segmented profit and loss statements that isolate the financial results of the relevant tested transactions. These s

🚨 Italian Supreme Court Recharacterizes Cash Pool as Loan (Case No. 998/2024) In a landmark decision, the Italian Supreme Court ruled...

Cash Pools Explained In this blog post, we will delve into the intricacies of cash pools. This video is the second in a series explaining their workings. Cash pools help organizations manage cash efficiently. By centralizing cash, companies can optimize their liquidity and investment opportunities. The Importance of Understanding Cash Pools Cash pools are essential for businesses of all sizes. They streamline cash management processes and enhance financial efficiency. Compani

Section 899 spells trouble for U.S. subsidiaries of foreign-parented companies. Much like the blunt instrument of reciprocal tariffs, its...

Cash pooling is a vital strategy for multinational corporations (MNCs) seeking to optimize liquidity management. This approach...

Understanding AI in Transfer Pricing The short answer: it's complicated. Yes, AI is a powerful technology, and the sooner we embrace it...

Introduction On May 22nd, the U.S. House of Representatives approved proposed Section 899 of the Internal Revenue Code—“Enforcement of...

The Trump administration's focus on tariff increases has the pharmaceutical industry grappling with a new reality and concern. Recently...

A few years ago I was inspired to write, compose and produce a song about BEPS. I never shared with it with my wider network, but I...

In this article, we will explore what debt capacity analysis is and why it is a critical component of financial analysis in the transfer...

Intellectual property (IP), also referred to as intangible property, constitutes a significant portion of companies’ profitability...

Intercompany financing is an area within transfer pricing that has faced increased scrutiny by tax authorities in recent years, primarily...