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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…

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…

Pillar Two – How (Global Minimum) Tax is embracing Tax Accounting

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…

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…

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


FAQs | Webinar | How to perform a segemented P&L analysis?

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…

Transfer pricing is all about substance – Industry Overview

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

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…

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…