Transfer pricing models implemented by Multinational Enterprises (MNE) often rely on the Transactional Net Margin Method (TNMM) to remunerate routine functions. A proper application of the TNMM involves the transfer

Transfer pricing adjustments and customs: the Chinese example

What future for rulings following the European Commission’s offensive?
At the time of Paradise Papers’ revelations about numerous tax schemes involving large international groups, it is interesting to look back at the activism of the European Commission, which has