The world and things keep changing, and this change is affecting the environment significantly – both positively and negatively, allowing and even forcing us to revise various processes and activities to make them consistent with the reality. These factors are also affecting transfer pricing (TP).

Related companies sometimes make loans to each other, and those must be arm’s length just like any other transaction between related parties. A benchmarking study can use both internal and external comparable data, yet it is not always clear what period those should be selected for. This article explores various types of loan analyses with benchmarking examples based on external sources of information.
 

The global tax scene has undergone some historic changes and keeps changing. This has caused multinational enterprise (MNE) groups to revise their global business models and take steps to stay competitive. Facing the evolution of technology, environmental changes and the impact of the pandemic, MNEs are beginning to revise and transform their value chains to make their business even more efficient and profitable.