Practical Implications for SMEs and Their Advisors As part of its 2026 tax reform, Cyprus has increased the thresholds that trigger a full transfer pricing Local File obligation under the Income Tax Law. The changes are intended to better align documentation requirements with transaction materiality and risk. For many SMEs, this means that a full Local File may no longer be required for certain categories of related-party transactions. However, the reform does not remove tran

Intercompany loans are a frequent and relatively straightforward area of challenge in US transfer pricing audits. Unlike more complex transfer pricing issues, related-party debt arrangements lend themselves to mechanical adjustments when basic legal, pricing, or behavioral requirements are not met. This note summarizes the key US transfer pricing rules that apply specifically to intercompany loans and highlights how the IRS approaches these arrangements in practice, particula

The Comparable Uncontrolled Price (CUP) method is often overlooked in favour of profit-based approaches like TNMM or CPM. Yet, when reliable comparable data exists, the CUP method is typically the preferred method under OECD Guidelines, IRS rules, and local regulations worldwide. For middle-market and entrepreneurial companies, correctly applying CUP can reduce risk, support pricing decisions, and improve audit defensibility.