In assessing assets, you should determine if these are present or owned by each party in the transaction and, if yes, to what extent. You should look at actual assets.…
Hank MoonenSeptember 14, 2022
Transfer pricing is all about substance - the functional analysis As per the OECD Transfer Pricing Guidelines (see the 5th bullet under section "Controlled transactions" OECD Transfer Pricing Guidelines for…
Hank MoonenAugust 30, 2022
Let‘s first start with the definition of "value chain" "The value chain describes the full range of activities companies and workers do to bring a product from its conception to…
Hank MoonenAugust 8, 2022
People (and the OECD) say transfer pricing is all about substance ... but how easy is this to understand substance in practice? Let me give a few examples based on…
Hank MoonenAugust 1, 2022
In the last couple of months, we have been approached by several multinationals and intermediaries, asking whether we were planning to build a Pillar Two / GloBE solution. Following this,…
TaxModelJune 8, 2022
The rapid shift towards digital tax administration is adding to the urgency for both intermediaries and multinationals to transform their workstreams from manual to digital. Tax authorities are increasingly exchanging…
Hank MoonenMay 20, 2022
During this webinar, we will present our understanding of the operative provisions of the Pillar Two GloBE Rules including a deep dive into the interaction between the IIR and UTPR,…
TaxModelMay 2, 2022
On March 14th, 2022, the Organization for Economic Co-operation and Development (OECD) released its Commentary on the Pillar Two Model Rules (the "P2 Commentary"). The Commentary on the GloBE Rules…
Hank MoonenApril 22, 2022
Dear Tax Professional, On December 20th, 2021, the OECD released the Pillar Two Model Rules. Pillar Two introduces new global minimum tax rules for multinational enterprises (MNEs) with an agreed…
Hank MoonenMarch 15, 2022
During this webinar, we will present our understanding of the operative provisions of the Pillar Two GloBE Rules including a deep dive into the Top-Up Tax calculations, and show how…
TaxModelMarch 14, 2022
If you wanted to get a feel for the content of a local file you previously had to download and synchronize the entire local file, and try to gather knowledge…
TaxModelMarch 14, 2022
