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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…
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…
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…
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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
FAQs: How to perform a segmented P&L analysis After our successful interactive transfer pricing webinar : How to perform a segmented P&L analysis, this blog post answers the questions…
How to outline Industry Overview in Transfer Pricing Documentation? In the industry overview of transfer pricing documentation, the multinational should provide a clear outline of the nature and the…
Transfer Pricing Documentation: All you need to know about value drivers As per Chapter V, Annex I of the OECD Transfer Pricing Guidelines, multinationals should provide information about their…
