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The Internal Revenue Service (IRS) recently issued a nonbinding Generic Legal Advice Memorandum (GLAM) that provides advice on Internal Revenue Code Section 482 and so-called implicit. ....
Carola Valente of Crowe Valente/Valente Associati GEB Partners explains the application of the OECD Transfer Pricing Guidelines to financial transactions as multinationals increasingly centralise their treasury functions ....
Viktoria Dimitrova and Alain Goebel of Arendt & Medernach reflect on the conclusions that may be drawn from the FIAT state aid case for TP purposes. ....