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Italian Supreme Court Recharacterizes Cash Pool Arrangement to Long/Term Medium Loan
🚨 Italian Supreme Court Recharacterizes Cash Pool as Loan (Case No. 998/2024) In a landmark decision, the Italian Supreme Court ruled...
Jun 30, 20251 min read


Understanding Cash Pools - Part 2
This video is the 2nd video in a series of videos that explain the inner workings of Cash Pools. This video discusses the short term...
Jun 29, 20251 min read


Proposed Section 899: A Retaliatory Tax Threat to U.S. Subsidiaries of Foreign MNEs
Section 899 spells trouble for U.S. subsidiaries of foreign-parented companies. Much like the blunt instrument of reciprocal tariffs, its...
Jun 25, 20251 min read


Unveiling Cash Pooling: Advantages and Insights for Multinational Corporations
Cash pooling is a vital strategy for multinational corporations (MNCs) seeking to optimize liquidity management. This approach...
Jun 20, 20253 min read


The Impact of AI on Transfer Pricing
Understanding AI in Transfer Pricing The short answer: it's complicated. Yes, AI is a powerful technology, and the sooner we embrace it...
Jun 4, 20252 min read


Proposed Section 899 and Its Potential Impact on BEAT and Transfer Pricing Adjustments
Introduction On May 22nd, the U.S. House of Representatives approved proposed Section 899 of the Internal Revenue Code—“Enforcement of...
May 23, 20252 min read


The Pharmaceutical Industry, Tariffs and Country of Origin
The Trump administration's focus on tariff increases has the pharmaceutical industry grappling with a new reality and concern. Recently...
Mar 15, 20253 min read


The BEPS 1.0 Song
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...
Mar 12, 20251 min read


The Critical Role of Debt Capacity Analysis in Transfer Pricing
In this article, we will explore what debt capacity analysis is and why it is a critical component of financial analysis in the transfer...
Mar 2, 20252 min read


Valuation and Management of Intellectual property within the Value Chain
Intellectual property (IP), also referred to as intangible property, constitutes a significant portion of companies’ profitability...
Feb 10, 20256 min read


Maximizing the Benefits of Intracompany Financing: What You Need to Know
Intercompany financing is an area within transfer pricing that has faced increased scrutiny by tax authorities in recent years, primarily...
Feb 5, 20254 min read


Transfer Pricing & Customs
Trump’s presidency has sparked a lot of recent discussions on customs and has brought this topic to the front lines. In fact, we may be...
Jan 26, 20252 min read
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