The end of transfer pricing mismatches

The arm’s length principle determines that the conditions agreed upon for intercompany transactions between entities that are part of a group must be businesslike....

Legislative proposal to combat transfer pricing mismatches

The Dutch government has recently held a public consultation on a legislative proposal in the area of transfer pricing (‘TP’). The proposal was already announced...

The Base Erosion and Profit Shifting (BEPS) project by the OECD

In 2013, the OECD announced the Base Erosion and Profit Shifting (BEPS) project. Its objective was to establish recommendations for better aligning profits, rather...

The unified approach under Pillar One as suggested by the OECD

In October 2019, the OECD published a discussion draft for a ‘Unified Approach’ under Pillar One. This document was an attempt by the OECD to advance discussion...

Allocation of profits to permanent establishments

If a company performs activities in a foreign jurisdiction, a permanent establishment (PE) may arise in that jurisdiction. Subsequently, (taxable) profit must be...

Potential impact of COVID-19 on your current transfer pricing model: Is action required?

First of all, we hope you and your families are staying safe and healthy during these challenging times. The impact of the COVID-19 outbreak has certainly been profound....