Transfer pricing audits conducted by tax authorities are no longer regarded as a purely formal exercise. In recent years, authorities have developed an increasingly analytical approach, based on detailed financial testing and a strict interpretation of the arm’s...
Transfer pricing regulations are mechanisms implemented by States to ensure that companies belonging to the same group operating in different countries cannot decide to artificially shift their profits in a particular country by adjusting the prices charged for...
The new regulation brings significant changes to transfer pricing rules and modifies the domestic framework for transfer pricing documentation in several areas. Below, we summarise the key elements of the decree and their practical implications. The new transfer...
Transfer pricing audits in Poland are a complex process that goes beyond a simple verification of documentation accuracy. These are multi-month projects in which tax authorities delve deeply into the group’s operating model, the role of the Polish entity, and the...
Transfer pricing rules are designed to ensure that intra-group transactions are carried out under arm's length criteria, ensuring an equitable allocation of profits and preventing the erosion of the tax base. For companies operating internationally, it is essential to...
Benchmarking analyses are an essential part of transfer pricing documentation, providing a reliable basis for ensuring that intercompany transactions comply with the arm's-length principle. For companies operating across borders, understanding how benchmarking works...
ETL GLOBAL is pleased to announce the release of the 2025/26 edition of its Transfer Pricing Guide, providing essential updates on transfer pricing rules across 25 jurisdictions. Developed by the ETL GLOBAL Transfer Pricing Group, led by Magdalena Dymkowska and Arely...
In a globalisation context and the increasing complexity of transnational transactions, the correct application of the transfer pricing policies has become a fundamental aspect for companies operating in multiple jurisdictions. For these purposes, the Benchmarking...
ETL GLOBAL Member Centrum Turkey has recently published its 2025 Transfer Pricing Guide, providing a summary of Türkiye’s current transfer pricing legislation, documentation obligations, and audit procedures. The guide sets out the core features of Türkiye’s transfer...
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