When you hear the term blockchain mentioned with respect to transfer pricing, it’s generally related to operational transfer pricing to ensure policies are in line. But if we think about what blockchain represents—a decentralized, immutable ledger—it opens up many other use cases for transfer pricing. One of the most powerful use cases I can think ...

For decades, both the Organization for Economic Cooperation and Development (OECD) and the United Nations (UN) have provided models for tax treaties between countries, and today, all existing tax treaties are based on the OECD model tax convention and/or the UN model. The essence of a tax treaty is to allocate taxing rights between countries ...

When speaking with customers, I regularly receive this question: Why should I redo my benchmarking search every three years? If nothing has changed, can’t I (or shouldn’t I) just keep refreshing the financial data of my comparables until something changes? It’s a fair question. After all, Chapter 5 of the OECD Guidelines (Paragraphs 5.37 and ...

Given the current volatile currency exchange rate landscape, and the approaching year-end for many, taxpayers should take the time to consider what implications it may have on transfer pricing. The first step is to review your intercompany agreements, and ensure they are aligned with how exchange rates are being handled operationally. In other words, do ...

Intercompany agreements (ICAs) have always been an important piece of transfer pricing compliance as they define the terms of intercompany transactions. However, in a volatile economic environment, when companies tend to inherit additional risk, these agreements become even more critical. “Intercompany agreements provide a reference to show what has happened in the external world and ...

OECD’s Two-Pillar solution appears to have more and more turning points as it is subject to global discussions on how the new tax rules should work to be efficient and fair. While some rules are gaining acceptance, others may become real deal-breakers. Many countries have had a hard time agreeing to Pillar One, which expands ...

Global inflation can add a layer of complexity to your transfer pricing documentation, especially if you’re using transaction-based methods to conduct your analyses. When relying on the sales of product or services to third parties as your comparables via the comparable uncontrolled price (CUP) or comparable uncontrolled transaction (CUT), cost plus (CP), or resale minus ...

It was more than 10 years ago, when I listened to a European transfer pricing expert, at a prestigious transfer pricing conference, talk about how he applies a cost-plus method with a cost-plus markup of 5% on fully loaded costs. I found myself confused because once you look at fully loaded costs, it’s really the ...

A new year always begins with a few good resolutions. But we weren’t interested in the usual diet and exercise promises—we wanted to see how tax executives will be upping their games in 2023. So, we asked clients and a few of our own experts about their professional new year’s resolutions and here we’re listing ...

Nowadays, transfer pricing compliance efforts pretty much cover the whole financial year: You start at the close of the previous financial year and gather all necessary information to prepare the annual master file and respective local files. For many countries you may have to prepare appendices or forms that summarize transfer pricing positions as part ...