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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…
A cross-border arrangement becomes reportable only if certain characteristics or features are present, referred to as ‘hallmarks.‘ Since most EU Member States have transposed definitions of hallmarks into their domestic…
How to prepare a segmented P&L analysis? As per Chapter V, Annex II of the OECD Transfer Pricing Guidelines, multinationals should provide financial information and allocation schedules showing how the…
Latest release notes
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…
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…
There are cases where you invoke your right of privilege as an intermediary. When you do this, you are relieved of the reporting duty. But, with this, you will have…
Latest transfer pricing news
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…
FAQs: The Future of Transfer Pricing - Benchmarks with AI After our successful interactive transfer pricing webinar : The future of Transfer Pricing - Benchmarks with AI, this blog post…
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…
