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HMRC clarifies approach to transfer pricing ranges – and why the median now matters

In November 2025, HMRC updated its International Manual (INTM485120), setting out a more structured approach to how case teams and taxpayers should apply ranges in transfer pricing analyses....more

OECD’s MAP and APA statistics. What 2024 has changed for Multinational Enterprises

Last year, in our article “OECD’s 2023 MAP and APA Statistics: Key Insights for Multinational Enterprises”, we analysed the inaugural global statistics on Advance Pricing Arrangements (APAs) alongside the longstanding mutual...more

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