Category: Blogs
Top four mistakes when preparing transfer pricing documentation and how to avoid them
Transfer pricing documentation is an essential tool to mitigate the risks of transfer pricing audits and disputes. It is crucial to prepare it correctly to avoid potential penalties, interest charges, and reputational damage. But even though compa...
Transfer pricing documentation is an essential tool to mitigate the risks of transfer pricing audits and disputes. It is crucia...
Read moreWhat is transfer pricing?
Transfer pricing entails many different aspects, which can be overwhelming to say the least. Not necessarily because the term transfer pricing itself is unclear, but because it covers a wide variety of sub-topics. In this blog we will cover the fu...
Transfer pricing entails many different aspects, which can be overwhelming to say the least. Not necessarily because the term t...
Read moreComparability analysis: more than only a benchmark study
A comparability analysis is an essential part of any transfer pricing analysis. Its purpose is to obtain an in-depth understanding of the significant characteristics of the controlled transaction and the roles of the respective parties involved wh...
A comparability analysis is an essential part of any transfer pricing analysis. Its purpose is to obtain an in-depth understand...
Read moreMajor developments in the Dutch transfer pricing landscape: an overview
In the past 10 years there have been major developments in the Dutch transfer pricing landscape. From the Dutch TP decree issued in November 2013 to a new Dutch TP decree in 2022. Or the implementation of the Master File and Local file in the Dutc...
In the past 10 years there have been major developments in the Dutch transfer pricing landscape. From the Dutch TP decree issue...
Read morePrice setting vs price testing; which TP method to apply?
The OECD distinguishes traditional transaction methods and transactional profit methods. The traditional transaction methods compare the intercompany price with the external price of a product or service (gross margin for Cost Plus and Resale Minu...
The OECD distinguishes traditional transaction methods and transactional profit methods. The traditional transaction methods co...
Read moreIntercompany services; do you provide an easy route to Transfer Pricing corrections?
Almost all groups are engaged in intercompany services to some extent. This could for example include administrative, commercial, financial, technical or head office services. In practice we often see that these intercompany services are insuffici...
Almost all groups are engaged in intercompany services to some extent. This could for example include administrative, commercia...
Read moreThe OECD BAPA Manual: focus on international alignment
On September 13th 2022 the OECD Forum on Tax Administration’s Bilateral Advance Pricing Arrangement Manual (“the BAPA Manual”) was approved by the OECD Committee on Fiscal Affairs. The manual covers almost 100 pages and addresses many issues that ...
On September 13th 2022 the OECD Forum on Tax Administration’s Bilateral Advance Pricing Arrangement Manual (“the BAPA Manual”) ...
Read moreWhat’s new? – New Decree on Profit Allocation for Permanent Establishments
The Netherlands recently published its new guidance on allocation of profits to a Permanent Establishment (“PE”). The existing guidelines for such profit allocation already showed that, next to the discussion on the existence of a PE the profit al...
The Netherlands recently published its new guidance on allocation of profits to a Permanent Establishment (“PE”). The existing ...
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