June 2026 An ongoing U.S. case is testing how far the IRS can go in restructuring a multinational's intercompany licence arrangements, and how much weight recent appellate reasoning should carry in that analysis. The case, Amgen Inc. v. Commissioner, concerns the pricing of intercompany licences between the pharmaceutical group's U.S. parent and its Puerto Rican manufacturing affiliate. The IRS argues that the arrangement understated the return owed to the U.S. entity, which owns the...

4 March 2026 A recent Italian Supreme Court case examined the burden of proof in transfer pricing disputes involving intra-group financing arrangements. The dispute concerned whether the Italian tax authorities had provided sufficient evidence to support a transfer pricing adjustment to the interest rate applied on a loan between related parties. The tax authorities argued that the interest rate charged did not reflect arm’s length conditions and sought to adjust the financing arrangement....

September 2025 A recent Swiss transfer pricing case examined whether taxpayers can rely on multi-year margin averaging when assessing compliance with the arm’s length principle. The dispute concerned the use of several years of financial results in a benchmarking analysis, rather than evaluating profitability on a year-by-year basis. The taxpayer argued that multi-year data provides a more reliable measure of economic performance by reducing the impact of temporary market fluctuations and...