The distinction between a related-party transaction and an ordinary business expense can have significant consequences for a company’s tax position. Two recent developments at Spain’s Supreme Court put that distinction under scrutiny, addressing the treatment of...
Public administration in the European Union has undergone a significant digital transformation over the past two decades, profoundly altering the manner in which citizens and businesses interact with government services. Poland is a prime example of this change,...
The transfer pricing rules in Hungary changed significantly at the end of 2025. Although Decree No. 45/2025 (XII. 23.) of the Ministry for National Economy did not change the basic structure of the transfer pricing documentation, which continues to consist of a Master...
With Order No. 13136 of 7 May 2026, the Italian Supreme Court issued an important ruling on transfer pricing and intra-group transactions. The Court held that a real guarantee granted by an Italian subsidiary in favour of a foreign parent company may fall outside the...
The issue of determining the “arm’s length” interest rate in the Republic of Serbia is regulated by the Corporate Income Tax Law and the Transfer Pricing Rulebook. In this context, the Corporate Income Tax Law provides that, in addition to the standard methods, a...
Transfer pricing is no longer shaped solely by guidelines and local regulations. Increasingly, court decisions across Europe are redefining how tax authorities interpret and challenge intra-group transactions. This is exactly why MDDP has prepared a comprehensive...
Transfer pricing regulations continue to evolve globally, with jurisdictions increasingly aligning with OECD standards while maintaining distinct local approaches to compliance and enforcement. This article provides a comparative overview of transfer pricing...
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...
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