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Better understand the mechanics of the PillarTwo/GloBE Rules? Download the simplified version of the examples from the OECD Commentary!

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…

The DAC6 hallmarks and the main benefit test

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…

Transfer pricing is all about substance – Preparing a segmented P&L analysis

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…

ATAD-3, the new EU Directive to tackle the misuse of shell entities (free flowchart)

On December 22, 2021, the European Commission published a draft Directive (link) to prevent the misuse of shell entities for improper tax purposes (hereafter referred to as "ATAD3"). ATAD3 should…

Latest release notes


Transaction specific information: Royalty & Financial Loan

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…

Release Note: Segmented P&L analysis

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…

DAC6pro Release Note: Notify Flow

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…

Release Note: Local comprehensive information

Comprehensive information can differ from local file to local file. Some countries simply require different information, and other countries might want a more in-depth look into some aspects of your…

Latest transfer pricing news


UK publishes new 2023 transfer pricing legislation

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 | Webinar | The Future of Transfer Pricing – Benchmarks with AI

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…

How can Brazilian entities prepare for and comply with the new Transfer Pricing regulations?

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…

2023 Transfer Pricing Regulations in Denmark

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…