Rob Rijnvos ⁽⁵⁾

Code of conduct on transfer pricing documentation for associated enterprises in the European Union (EU TPD) Without prejudice to the respective spheres of competence of the Member States and the Community, this Code of Conduct concerns the implementation of standardised and partially centralised transfer pricing…

When a company does business in another country through a fixed place there, it can create a permanent establishment (PE). The host country may then tax the profits of that PE, even though it is not a separate legal entity. Most tax treaties follow Article…

What are head office costs? When a head office manages other entities within the group, you will very likely run into the terms head office and head office costs. Central decision-making and, for example, administration are typical head office costs. The allocation of head office…

All three methods look for the price independent parties would have agreed. They just test it on a different line of the income statement. The deeper you measure, the looser the comparability requirements, but the more lies between the price and the point you measure.

Since 2024 a growing number of countries apply a global minimum tax of 15% to large multinational groups. The rules come from Pillar Two of the OECD/G20 Inclusive Framework and are known as the Global Anti-Base Erosion (GloBE) rules. This article explains how they work…