News & Blogs
Pillar One, Amount B: “The rise of the secret comparables?”
On 17 July 2023, the OECD/IF published the public consultation document for Pillar One, Amount B. The objective of this consultation document is to simplify the pricing of baseline marketing and distribution activities, to increase tax certainty for businesses, and to minimise conflicts between taxpayers and tax administrations. Unlike Pillar Two, there is no revenue threshold […]
Comparability 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 which is needed in determining and substantiating the arm’s length remuneration of a controlled transaction. Performing a comparability analysis consists of […]
What’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 allocation itself, it is often not an easy exercise and has an embedded tax audit risk. This […]
Transfer pricing documentation update: now is the right moment to act!
Most countries require companies to prepare transfer pricing documentation on a yearly basis. This relates for example to the master file, local files, and other local transfer pricing forms. It is important to meet these yearly documentation requirements in order to prevent the potential consequences of non-compliance such as penalties, shifts in the burden of proof and […]