HMRC has recently published a law to implement changes for the transfer pricing records in the UK. The changes were published on July 19th and are in force since August…
Lisanne ValksAugust 17, 2023
In a previous blog we referred to the impact of the potential introduction of the Transfer Rricing (TP) regulations (Provisional Measure No. 1152, of 2022) issued on 28 December 2022…
Sonia MuñozJuly 18, 2023
In 2021, Denmark introduced a transfer pricing requirement to submit the transfer pricing documentation to the Danish Tax Administration. This blog aims to shed light on the key elements to…
Lisanne ValksJune 26, 2023
Pillar 2 elections explained In this blog series we explain the Pillar 2 elections as prescribed in Global Anti-Base Erosion Model Rules (Pillar Two) Pillar 2 election to spread capital…
Hank MoonenApril 19, 2023
Pillar 2 elections explained In this blog series we explain the Pillar 2 elections as prescribed in Global Anti-Base Erosion Model Rules (Pillar Two) Realization Method instead of Fair Value…
Hank MoonenApril 11, 2023
What are the Pillar 2 safe harbour tests? The Pillar 2 GloBE regulations, as published by the OECD on 20 December 2021, contain the following safe harbour tests: Minimum Revenue…
Hank MoonenApril 10, 2023
Pillar 2 elections explained In this blog series we explain the computation of GloBE Income or Loss as prescribed in Global Anti-Base Erosion Model Rules (Pillar Two) Pillar 2 stock-based…
Hank MoonenApril 6, 2023
Royalty Each transaction type requires different information to be communicated in your local file. Until now, it was impossible to add this transaction-specific information to TPdoc. But, we have developed…
TaxModelApril 4, 2023
One of the hardest aspects of transfer pricing is to reconcile the financial performance of intercompany transactions with the statutory financial statements of a company. Typically, this is done by…
TaxModelMarch 20, 2023
On 28 December 2022, the Brazilian Government issued the draft legislation, Provisional Measure No. 1152, of 2022 with the aim of changing the corporate income tax legislation (IRPJ) by revoking…
Sonia MuñozFebruary 27, 2023
In a major step forward on 8 October 2021, over 135 Inclusive Framework members, representing more than 95% of global GDP, joined a two-pillar solution to reform international tax rules…
Hank MoonenFebruary 27, 2023
