Transfer Pricing Archives - Page 2 of 5 - TaxModel, a Tax Systems Company

Blog Transfer Pricing

Transfer Pricing Deadlines – Poland (2023)

Entities obliged to prepare group transfer pricing documentation (2023) Article 11p of the CIT Act The threshold for Master File obligations has been abolished. From the new tax year, related…

TaxModelOctober 28, 2022

Blog Transfer Pricing

Remember the important changes in Italy’s transfer pricing documentation requirements!

On 26 November 2021, the Italian Tax Authorities issued a Circular Letter providing clarifications on the new instructions introduced in November 2020 regarding the content and validity of the elective…

TaxModelOctober 6, 2022

Blog Transfer Pricing

Transfer pricing is all about substance – How to perform a DEMPE analysis

BestBikes, a super-premium bicycle brand, has entities throughout Europe. The group develops a new bicycle, owned and promoted by the German principal entity of the group, BestBikes International GmbH ("BBINT").…

Hank MoonenOctober 6, 2022

Blog Transfer Pricing

The economic intent of intercompany financial transactions

When analyzing financial transactions between affiliated parties, it is essential to consider the economic context or the economic rationale for the existence of such intercompany dealing. There is, in most…

Hank MoonenSeptember 27, 2022

Blog Transfer Pricing

Cyprus introduces transfer pricing rules and documentation requirements

Cyprus introduces transfer pricing rules and documentation requirements On 30 June 2022, the House of Representatives of Cyprus voted on and approved amendments to the Income Tax Law and the…

Hank MoonenSeptember 22, 2022

Blog Transfer Pricing

How to perform an assets assessment within a functional Analysis

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

Blog Transfer Pricing

Functional Analysis in Transfer Pricing

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

Blog Transfer Pricing

Transfer Pricing is all about substance, how it should align with the value chain!

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

Blog Transfer Pricing

Transfer Pricing substance in practice

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

Blog Release notes Transfer Pricing

âï¸ NEW: TPdoc builds Master- and Local Files in MS Word in less than 1 minute!

How does your firm or in-house tax team commit to high-quality transfer pricing documentation and keeping deadlines while compliance is exploding and budgets are dropping? Transfer pricing efforts are moving…

Hank MoonenJanuary 4, 2022

Blog Transfer Pricing

8 reasons for intermediaries to consider automation for TP documentation

Why digitalizing your documentation workstreams? The importance of transfer pricing and the rapid shift towards a digital tax administration brings urgency for intermediaries to transform their documentation workstreams from manual…

TaxModelOctober 14, 2021

Blog Transfer Pricing

Transfer Pricing Country Update: Hungary

Legal Basis The Hungarian transfer pricing ("TP") legislation is in Act LXXXI of 1996 on Corporate Tax and Dividend Tax, Section 18 in different Decrees, as well as in the…

TaxModelSeptember 2, 2021

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Transfer Pricing

Transfer Pricing Deadlines – Poland (2023)

Remember the important changes in Italy’s transfer pricing documentation requirements!

Transfer pricing is all about substance – How to perform a DEMPE analysis

The economic intent of intercompany financial transactions

Cyprus introduces transfer pricing rules and documentation requirements

How to perform an assets assessment within a functional Analysis

Functional Analysis in Transfer Pricing

Transfer Pricing is all about substance, how it should align with the value chain!

Transfer Pricing substance in practice

âï¸ NEW: TPdoc builds Master- and Local Files in MS Word in less than 1 minute!

8 reasons for intermediaries to consider automation for TP documentation

Transfer Pricing Country Update: Hungary

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