# TPGenie - Transfer Pricing Documentation Software > Transfer Pricing Documentation Software --- ## Pages - [Services](https://intrapricing.com/services-transfer-pricing/): Transfer Pricing Services Transfer Pricing Services Powered by TPGenie At Intra Pricing Solutions, we deliver comprehensive transfer pricing services that... - [Compliance Tracker](https://intrapricing.com/products/compliance-tracker/): Manage global transfer pricing compliance with TPGenie’s Compliance Tracker. Customise country-specific tax requirements, automate risk assessments, and track deadlines for... - [Reconciliation Module](https://intrapricing.com/products/reconciliation-module/): Manage and reconcile your global transfer pricing data with TPGenie’s Reconciliation Module. Designed for Transfer Pricing managers, this module allows... - [Transfer Pricing Copilot](https://intrapricing.com/products/tp-copilot/): Experience the future of transfer pricing with TP Copilot, an AI-Powered validation Module. TP Copilot integrated with TPGenie enhances transfer... - [Modules](https://intrapricing.com/software-modules/): Products Modules - [TPGenie Benchmarking AI - Cost savings calculator](https://intrapricing.com/products/transfer-pricing-and-benchmarking-ai-tools/cost-savings-calculator/): Explore the financial benefits of integrating TPGenie Benchmarking AI into your transfer pricing benchmarking process through our cost savings calculator.... - [Pillar Two](https://intrapricing.com/products/pillar-two/): Navigate the complexities of global minimum tax with our innovative tool. Designed for multinational enterprises and tax - [Transfer Pricing Benchmarking AI](https://intrapricing.com/products/transfer-pricing-and-benchmarking-ai-tools/): Artificial Intelligence (A. I. ) tools for speeding up your benchmarking process, crawling and translating company websites. - [Vanderlande Industries](https://intrapricing.com/customers/vanderlande-industries/): Customer Success Story Since 2021 Vanderlande Industries is using TPGenie Enterprise, including inter-company Agreement Database, currency conversion, CbCR and translation... - [test contact](https://intrapricing.com/test-contact/) - [Legal Entity Management](https://intrapricing.com/products/legal-entity-management/): The Legal Entity Management (LEM) Module is an easy to use cloud solution that enables you to manage your legal... - [H&M](https://intrapricing.com/customers/hmgroup/): Customer Success Story Since 2014 H&M is using TPGenie Enterprise and is development partner of TPGenie. H&M - [Cookie Policy (EU)](https://intrapricing.com/cookie-policy-eu/) - [Transfer Pricing Data Security](https://intrapricing.com/data-security/) - [BOBST](https://intrapricing.com/customers/bobst/): Customer Success Story - [Nouryon](https://intrapricing.com/customers/nouryon/): Customer Success Story - [Basefirma](https://intrapricing.com/customers/basefirma/): Customer Success - [TPA Global](https://intrapricing.com/customers/tpa-global/): Customer Success Story - [Triumph](https://intrapricing.com/customers/triumph/): Customer Success Story - [AkzoNobel](https://intrapricing.com/customers/akzonobel/): Customer Success Story - [API](https://intrapricing.com/developers/api/): TPGenie API Reference As a developer, you can build a variety of integrations with the TPGenie API. The integrations allow... - [Wolter Koops](https://intrapricing.com/customers/wolter-koops/): Customer Success Story Since 2015 Wolter Koops Group uses TPGenie Enterprise. Wolter Koops operates in the international controlled-temperature transport and - [Blog](https://intrapricing.com/blog/): Transfer Pricing Blog - [TPGenie Partner Program](https://intrapricing.com/about-us/tpgenie-partner-program/): TPGenie Partner Program The TPGenie partner program rewards you with a range of benefits that - [Developers](https://intrapricing.com/developers/): Integrate TPGenie into your company’s systems and build powerful apps. Use APIs to connect your applications to TPGenie. - [Ewals Cargo Care](https://intrapricing.com/customers/ewals-cargo-care/) - [Customers](https://intrapricing.com/customers/): See how TPGenie increases efficiency and reduces costs. A selection of our customers - [TPGenie Integrations](https://intrapricing.com/developers/integrations/) - [TPGenie Business](https://intrapricing.com/products/tpgenie-business/): Transfer Pricing documentation & client management tool for Tax Advisors & Transfer Pricing Services Providers - [TPGenie Enterprise](https://intrapricing.com/products/tpgenie-enterprise/): Transfer Pricing Documentation Softwarefor multinationals Unlimited users Unlimited entities and countries Workflow Free country - [Transfer Pricing Benchmarking Database](https://intrapricing.com/products/transfer-pricing-benchmarking-database/): Transfer Pricing Benchmarking Database The Transfer Pricing Benchmarking Database is a module which takes the complicated process of performing an... - [Translation Module](https://intrapricing.com/products/translation-module/): An automatic translation module helps generating Master file, Local files, Intercompany Agreements or any other documents in different languages and... - [Country-by-Country Reporting Software Tool](https://intrapricing.com/products/country-by-country-reporting-software-tool/): The Country-by-Country Reporting (CbCR) Software Tool creates a BEPS Action 13 CbCR in the XML format according to specifications of... - [Currency Conversion Module](https://intrapricing.com/products/currency-conversion-module/): This module provides an ability to change financials uploaded in a local amount to transaction amount and vice versa as... - [Intercompany Agreements database](https://intrapricing.com/products/intercompany-agreements-database/): This module is an intercompany agreement management repository and provides numerous of functionalities for managing your intercompany agreements. Easily show - [Create Intercompany Agreements](https://intrapricing.com/products/create-intercompany-agreements/) - [Contact](https://intrapricing.com/contact/) - [TPGenie Basic](https://intrapricing.com/products/tpgenie-basic/): Transfer Pricing Documentation Softwarefor local entities or tax advisory companies 1 - [About us](https://intrapricing.com/about-us/): Who we are Intra Pricing Solutions is an independent and specialist provider of transfer pricing related software - [Home](https://intrapricing.com/) - [Products](https://intrapricing.com/products/): TPGenie Products --- ## Posts - [TP Copilot: Using AI to Cross-Check Local File with CbCR](https://intrapricing.com/blog/tp-copilot-cross-checking-local-file-with-cbcr/): One of the most common risks in transfer pricing documentation is inconsistency between the Local File and the Country-by-Country Report... - [TP Copilot: More Than Validation – Your AI Partner for Transfer Pricing Compliance](https://intrapricing.com/blog/tp-copilot-more-than-validation-your-ai-partner-for-transfer-pricing-compliance/): In transfer pricing, details matter. A small mismatch between a TP Form and a Local File can trigger extensive audits,... - [TPGenie Compliance Tracker: Expanded with New FY2025 Data Fields](https://intrapricing.com/blog/tpgenie-compliance-tracker-expanded-with-new-fy2025-data-fields/): At TPGenie, we continuously enhance our platform to give multinational enterprises (MNEs) and tax professionals the tools they need to... - [Closing the Gap Between Local Files and TP Forms](https://intrapricing.com/blog/closing-the-gap-between-local-files-and-tp-forms/): Why TP Forms matter in Transfer Pricing compliance In global Transfer Pricing compliance, attention often goes to preparing strong local... - [Six Ways AI Helps Catch Transfer Pricing Mistakes You Might Miss](https://intrapricing.com/blog/six-ways-ai-helps-catch-transfer-pricing-mistakes-you-might-miss/): Even the most experienced transfer pricing professionals face challenges in ensuring flawless documentation. Hidden pitfalls like inconsistent profit margins, outdated... - [Transfer Pricing - from Templates to Intelligence: Utilizing your AI Copilot](https://intrapricing.com/blog/transfer-pricing-from-templates-to-intelligence-utilizing-your-ai-copilot/): Transfer pricing documentation has come a long way from clunky Word templates and last-minute data chasing. As global regulations tighten... - [Why the Next Generation of TP Professionals Will Be AI-Native](https://intrapricing.com/blog/why-the-next-generation-of-tp-professionals-will-be-ai-native/): The transfer pricing landscape is undergoing a rapid transformation. As data volumes grow and regulatory demands intensify, TP professionals are... - [How AI is Powering Smarter TP Documentation – A Behind-the-Scenes Look at TPGenie](https://intrapricing.com/blog/how-ai-is-powering-smarter-tp-documentation-a-behind-the-scenes-look-at-tpgenie/): In the evolving world of transfer pricing, the burden of documentation has grown heavier, more jurisdictions, more complexity, tighter deadlines.... - [Top 10 Transfer Pricing Documentation Tools in 2025](https://intrapricing.com/blog/top-10-transfer-pricing-documentation-tools-in-2025/): In 2025, transfer pricing compliance continues to be a core challenge for multinational enterprises (MNEs), particularly within the EU where... - [The Future of Transfer Pricing is AI-Driven and Here’s Why](https://intrapricing.com/blog/the-future-of-transfer-pricing-is-ai-driven-and-heres-why/): AI is opening up new possibilities for transfer pricing. It’s not just about keeping up with compliance anymore, it’s about... - [Now Live in TPGenie: The German Transfer Pricing Transaction Matrix](https://intrapricing.com/blog/now-live-in-tpgenie-the-german-transfer-pricing-transaction-matrix/): TPGenie continues to lead the way in streamlining global transfer pricing compliance — and we’re excited to announce our latest... - [Can AI Really Understand the Arm’s Length Principle?](https://intrapricing.com/blog/can-ai-really-understand-the-arms-length-principle/): AI is no longer a “nice to have” in transfer pricing, it’s already here, reshaping how tax teams handle documentation,... - [The Future of Transfer Pricing AI: How Artificial Intelligence and Data Are Transforming Global Tax Compliance](https://intrapricing.com/blog/the-future-of-transfer-pricing-ai-how-artificial-intelligence-and-data-are-transforming-global-tax-compliance/): As global tax regulations grow more complex, the world of transfer pricing is undergoing a major transformation—powered by artificial intelligence.... - [Say Goodbye to TP Documentation Headaches](https://intrapricing.com/blog/say-goodbye-to-tp-documentation-headaches/): Imagine creating transfer pricing documents that practically write themselves. That’s exactly what our April 2025 update at TPGenie delivers. The... - [TPGenie Users Day 2025: Collaboration, Innovation, and the Future of Transfer Pricing Technology](https://intrapricing.com/blog/tpgenie-users-day-2025-collaboration-innovation-and-the-future-of-transfer-pricing-technology/): Last week, we had the pleasure of hosting the TPGenie Users Day 2025, bringing together transfer pricing professionals from across... - [Data and Technology in Transfer Pricing: Transforming Compliance and Strategy](https://intrapricing.com/blog/data-and-technology-in-transfer-pricing-transforming-compliance-and-strategy/): In today’s interconnected world, data and technology are revolutionizing the way multinational enterprises (MNEs) approach transfer pricing. The increasing complexity... - [Regulatory Changes and Audits in Transfer Pricing: Staying Ahead of Compliance](https://intrapricing.com/blog/regulatory-changes-and-audits-in-transfer-pricing-staying-ahead-of-compliance/): Transfer pricing continues to be a top priority for tax authorities worldwide, with regulations evolving and audit scrutiny intensifying. For... - [Global Transfer Pricing Disputes: Navigating Complex Challenges](https://intrapricing.com/blog/global-transfer-pricing-disputes-navigating-complex-challenges/): Transfer pricing disputes have become a critical area of focus for multinational enterprises (MNEs) as tax authorities worldwide ramp up... - [New P&L Segmentation Feature Makes Transfer Pricing Documentation Easier](https://intrapricing.com/blog/new-pl-segmentation-feature-makes-transfer-pricing-documentation-easier/): P&L Segmentation Tool The P&L Segmentation Tool enables organisations to build, manage, and populate segmented Profit & Loss statements within... - [P&L Segmentation in Transfer Pricing: The Ultimate Guide for 2025](https://intrapricing.com/blog/pl-segmentation-in-transfer-pricing-the-ultimate-guide-for-2025/): Understanding P&L Segmentation for Transfer Pricing Compliance P&L segmentation represents a critical component of transfer pricing documentation for multinational enterprises... - [Mastering the Challenges of Cross-Border Intercompany Financing](https://intrapricing.com/blog/mastering-the-challenges-of-cross-border-intercompany-financing/): In today’s interconnected global economy, cross-border intercompany financing has become a cornerstone of multinational enterprises (MNEs) seeking to optimize their... - [Global Transfer Pricing Disputes: How Transfer Pricing Documentation Software Can Mitigate Risks](https://intrapricing.com/blog/global-transfer-pricing-disputes-how-transfer-pricing-documentation-software-can-mitigate-risks/): As the global trade keeps evolving, tax authorities around the world have become more vigilant in scrutinizing transfer pricing practices.... - [Increased Scrutiny on Intangibles in Global Transfer Pricing: The Role of Transfer Pricing Documentation Software](https://intrapricing.com/blog/increased-scrutiny-on-intangibles-in-global-transfer-pricing-the-role-of-transfer-pricing-documentation-software/): In today’s global economy, intangible assets—such as intellectual property (IP), brand value, and proprietary technologies—have become pivotal drivers of value... - [Digital Economy and Transfer Pricing: Navigating Complexities with Transfer Pricing Documentation Software](https://intrapricing.com/blog/digital-economy-and-transfer-pricing-navigating-complexities-with-transfer-pricing-documentation-software/): The digital economy has fundamentally transformed global business landscapes, enabling companies to operate seamlessly across borders and leverage digital assets... - [Introducing Transfer Pricing Copilot for TPGenie](https://intrapricing.com/blog/introducing-transfer-pricing-copilot-for-tpgenie/): We are proud to announce the release of TP Copilot, an AI-powered module now integrated into TPGenie, designed to check... - [Supply Chain Disruptions and Inflation in Transfer Pricing](https://intrapricing.com/blog/supply-chain-disruptions-and-inflation-in-transfer-pricing/): Global supply chain disruptions, inflationary pressures, geopolitical tensions, and global elections have emerged as significant challenges in the recent world... - [Sustainability, ESG, and Transfer Pricing](https://intrapricing.com/blog/sustainability-esg-and-transfer-pricing/): As environmental, social, and governance (ESG) factors continue to gain prominence in the global business landscape, multinational enterprises (MNEs) are... - [A Fresh New Look for TPGenie and Intra Pricing Solutions](https://intrapricing.com/blog/a-fresh-new-look-for-tpgenie-and-intra-pricing-solutions/): Last month marked an exciting chapter for Intra Pricing Solutions and TPGenie, our flagship Transfer Pricing Documentation solution. After months... - [Understanding Pillar Two Software: A Key Tool for Global Tax Compliance](https://intrapricing.com/blog/understanding-pillar-two-software-a-key-tool-for-global-tax-compliance/): The Pillar Two regulations, part of the OECD’s Global Anti-Base Erosion (GloBE) framework, require multinational enterprises to calculate and report... - [Unlocking Transfer Pricing Compliance: The power of the TPGenie compliance tracker tool](https://intrapricing.com/blog/unlocking-transfer-pricing-compliance-the-power-of-the-tpgenie-compliance-tracker-tool/): Compliance with transfer pricing regulations across multiple countries presents a complex challenge for organizations operating and planning to expand internationally.... - [The Integration of AI and LLMs into Transfer Pricing: Transforming Documentation, Benchmarking, and Risk Management](https://intrapricing.com/blog/the-integration-of-ai-and-llms-into-transfer-pricing-transforming-documentation-benchmarking-and-risk-management/): Over the last decade there has been a significant increase in the domain transfer pricing regulations and compliance requirements. The... - [Transfer Pricing Documentation with TPGenie: The Leading Transfer Pricing SaaS Solution](https://intrapricing.com/blog/transfer-pricing-documentation-with-tpgenie-the-leading-transfer-pricing-saas-solution/): Transfer pricing is one of the most critical tax issues faced by multinational enterprises (MNEs) today. As regulatory scrutiny intensifies... - [Upcoming Design Update for TPGenie](https://intrapricing.com/blog/upcoming-design-update-for-tpgenie/): In the coming month, TPGenie will undergo a significant visual update. After months of dedicated work, the team is ready... - [TPGenie's Next-Gen Interface](https://intrapricing.com/blog/tpgenies-next-gen-interface/): TPGenie, your trusted companion in writing and automating transfer pricing documentation, is ready for a transformative leap. After more than... - [VIDEO: Revolutionise your transfer pricing benchmarking with TPGenie Benchmarking AI!](https://intrapricing.com/blog/video-revolutionise-your-transfer-pricing-benchmarking-with-tpgenie-benchmarking-ai/): Say farewell to the time-consuming manual process and embrace a new era of precision and efficiency. Our AI-driven solution not... - [TPGenie Benchmarking AI for Transfer Pricing: Frequently Asked Questions](https://intrapricing.com/blog/tpgenie-benchmarking-ai-for-transfer-pricing-frequently-asked-questions/): Welcome to the FAQ section for TPGenie Benchmarking AI, your comprehensive solution for transfer pricing studies. Below, you’ll find detailed... - [Results of automating Transfer Pricing Benchmarking using Artificial Intelligence (AI): 95% accuracy!](https://intrapricing.com/blog/results-of-automating-transfer-pricing-benchmarking-using-artificial-intelligence-ai-95-percent-accuracy/): Enter TPGenie Benchmarking AI, a solution that is revolutionizing how transfer pricing experts approach their benchmarking studies, enhancing accuracy, efficiency,... - [New feature: Upload External Benchmark](https://intrapricing.com/blog/new-feature-upload-external-benchmark/): TPGenie introduces the Upload External Benchmark feature, streamlining the process of importing and analysing transfer pricing benchmark data. This new... - [Streamlining Transfer Pricing Documentation with TPGenie: A Future-Proof Solution for Tax Managers and Experts](https://intrapricing.com/blog/streamlining-transfer-pricing-documentation-with-tpgenie-a-future-proof-solution-for-tax-managers-and-experts/): In the realm of transfer pricing, the challenges of standardisation and automation are paramount. With the introduction of TPGenie, a... - [Boost Your Transfer Pricing Benchmarking: TPGenie's BenchmarkAI-Powered Solution Saves Time and Delivers Precise Results](https://intrapricing.com/blog/boost-your-transfer-pricing-benchmarking-tpgenies-benchmarkai-powered-solution-saves-time-and-delivers-precise-results/): Supercharge your transfer pricing benchmarking with TPGenie’s latest features: BenchmarkAI, our cutting-edge AI technology driven by OpenAI’s ChatGPT revolutionizes the... - [A solution for the new transfer pricing regulations in Moldova](https://intrapricing.com/blog/a-solution-for-the-new-transfer-pricing-regulations-in-moldova/): In December 2022, The Republic of Moldova officially implemented its inaugural transfer pricing regulations, marking a significant development for businesses... - [An increased focus on Transfer Pricing audits](https://intrapricing.com/blog/an-increased-focus-on-transfer-pricing-audits/): As transfer pricing-related tax audits become more prevalent, multinational companies (MNE’s) are facing heightened scrutiny in maintaining comprehensive audit trails... - [Newest trends in the transfer pricing world](https://intrapricing.com/blog/newest-trends-in-the-transfer-pricing-world/): The transfer pricing world is constantly evolving. The pace of change in the transfer pricing world appears to be accelerating... - [Optimizing Your TP Documentation Process: Introducing TPGenie's Time Comparison Graph!](https://intrapricing.com/blog/optimizing-your-tp-documentation-process-introducing-tpgenies-time-comparison-graph/): In today’s fast-paced business world, time is a valuable resource. We’ve been diligently observing our users and are delighted to... - [Download free Transfer pricing policy template](https://intrapricing.com/blog/download-free-transfer-pricing-policy-template/): A polished and professionally drafted transfer pricing policy document is a key ingredient in your compliance process. This could be... - [The link between transfer pricing and carbon trading](https://intrapricing.com/blog/the-link-between-transfer-pricing-and-carbon-trading/): Environmental taxation and the treatment of carbon as part of an MNE’s value chain could be one of the most... - [Transfer pricing and interest rate changes in real estate](https://intrapricing.com/blog/transfer-pricing-and-interest-rate-changes-in-real-estate/): Inflation has been on an upward curve over the last few years and most central banks have followed with changing... - [An effective way to deal with the changes in transfer pricing regulations in the UAE](https://intrapricing.com/blog/an-effective-way-to-deal-with-the-changes-in-transfer-pricing-regulations-in-the-uae/): In the beginning of 2022, the Ministry of Finance (MoF) of the United Arab Emirates declared that they would introduce... - [Streamline Transfer Pricing Compliance with TPGenie: A Solution for Brazilian MNEs](https://intrapricing.com/blog/streamline-transfer-pricing-compliance-with-tpgenie-a-solution-for-brazilian-mnes/): As a CFO or Global Head of Tax or Transfer Pricing expert working in a Brazilian multinational enterprise (MNE), you... - [Approaching the challenges of transfer pricing in an effective manner](https://intrapricing.com/blog/approaching-the-challenges-of-transfer-pricing-in-an-effective-manner/): Transfer pricing is undoubtably a key focus area in the international business community. Supply chain transformation, trade wars and regionalisation... - [Your multinational enterprise’s (MNE’s) transfer pricing documentation strategy: Centralised vs Local approach](https://intrapricing.com/blog/your-multinational-enterprises-mnes-transfer-pricing-documentation-strategy-centralised-vs-local-approach/): In the past three decades, multinational companies have experienced no business function that grinds so deeply into all international operations... - [A productive way to increase your turnover as a tax-advisor](https://intrapricing.com/blog/a-productive-way-to-increase-your-turnover-as-a-tax-advisor/): Tax advisors can create transfer pricing documentation for their clients. By doing this they could add an additional service to... - [What is Tax Tech and how does TPGenie fit in?](https://intrapricing.com/blog/what-is-tax-tech-and-how-does-tpgenie-fit-in/): As of late tax technology have increased functionality and reporting capabilities for companies. These tax specific systems deliver a variety... - [Revolutionizing Transfer Pricing Documentation: TPGenie Launches AI Writing Assistant with ChatGPT Integration](https://intrapricing.com/blog/revolutionizing-transfer-pricing-documentation-tpgenie-launches-ai-writing-assistant-with-chatgpt-integration/): TPGenie, the innovative transfer pricing documentation tool, has just launched a game-changing feature: an AI writing assistant powered by ChatGPT.... - [Things to consider when purchasing transfer pricing software](https://intrapricing.com/blog/things-to-consider-when-purchasing-transfer-pricing-software/): When purchasing a transfer pricing documentation tool, there are several important success factors to consider. Reliability and accuracy The tool... - [What is transfer pricing?](https://intrapricing.com/blog/what-is-transfer-pricing/): Transfer pricing (TP) encompasses the rules and conditions that dictate transactions within a Multinational Enterprise (MNEs). Primarily it concerns the... - [ChatGPT and Transfer Pricing benchmarking](https://intrapricing.com/blog/chatgpt-and-transfer-pricing-benchmarking/): Transfer Pricing benchmarking studies require a considerable amount of data and information about the companies being compared. The more accurate... - [ChatGPT in transfer pricing software TPGenie](https://intrapricing.com/blog/chatgpt-in-transfer-pricing-software-tpgenie/): TPGenie has made a significant leap towards automation and artificial intelligence by seamlessly incorporating ChatGPT – a state-of-the-art natural language... - [How to stay updated with Transfer Pricing Regulations?](https://intrapricing.com/blog/how-to-stay-updated-with-transfer-pricing-regulations/): The Organisation for Economic Co-operation and Development (OECD) project on base erosion and profit sharing has caused an increased interest... - [How to automate transfer pricing documentation processes?](https://intrapricing.com/blog/how-to-automate-transfer-pricing-documentation-processes/): Automation of your Transfer Pricing documentation process can be challenging exercise. The importance of data and the help it gives... - [Pixel Perfect Document Formatting with TPGenie](https://intrapricing.com/blog/pixel-perfect-document-formatting-with-tpgenie/): TPGenie has a powerful tool that offers document formatting features to enhance the overall look and feel of outputted documents.... - [Summary of the OECD Transfer Pricing guidelines](https://intrapricing.com/blog/summary-of-the-oecd-transfer-pricing-guidelines/): The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations were first implemented in 1995, with the intent to... - [Transfer Pricing Software vs. Consultants](https://intrapricing.com/blog/transfer-pricing-software-vs-consultants-the-pros-and-cons-of-using-tp-software/): Transfer pricing software vs consultants are the two sought-after methods for managing the complexities of a multinational enterprise’s transfer pricing... - [What is interest rate benchmarking transfer pricing?](https://intrapricing.com/blog/what-is-interest-rate-benchmarking-transfer-pricing/): A challenging year We are fast approaching the end of a challenging 2022. We can approach 2023 with energy and... - [What is a fiscal unity?](https://intrapricing.com/blog/what-is-a-fiscal-unity/): Albert Einstein and taxes Taxes has throughout the ages been a major point of debate. Every country has their unique... - [Convert Excel to Form 8975 Country-by-Country Report filing](https://intrapricing.com/blog/convert-excel-to-form-8975-country-by-country-report-filing/): TPGenie software is prepared to generate Country-by-Country Reporting Form 8975 and Schedules A (Form 8975), holding Tax Jurisdiction and Constituent... - [TPGenie + Public CbC](https://intrapricing.com/blog/tpgenie-public-cbc/): TPGenie is prepared to flag for Public Country by Country Reporting. Public CbC will be in place for the MNE... - [How to perform a Transfer Pricing benchmarking study](https://intrapricing.com/blog/how-to-perform-a-transfer-pricing-benchmarking-study/): Benchmarking study or comparability analysis is the heart of the application of the arm’s length principle. Application of the arm’s... - [ISO 27001 certification](https://intrapricing.com/blog/iso-27001-certification/): Intra Pricing Solutions BV is in the process of ISO 27001 certification. The goal is to receive the certification by... - [Compare Transfer Pricing databases](https://intrapricing.com/blog/compare-transfer-pricing-databases/): Multinational enterprises across the globe have to comply with transfer pricing documentation requirements. To provide the documentation which is fully... - [Software update: Eastern Europe Transfer Pricing Benchmarking Database](https://intrapricing.com/blog/software-update-eastern-europe-transfer-pricing-benchmarking-database/): As businesses continue to expand globally, transfer pricing has become an increasingly important topic for multinational enterprises. To assist companies... - [What is a Transfer Pricing Policy template?](https://intrapricing.com/blog/what-is-a-transfer-pricing-policy-template/): A transfer pricing policy template is a document that provides a framework for setting transfer pricing policies within an organization.... - [Benefits of using TPGenie and having an external tax advisor](https://intrapricing.com/blog/benefits-of-using-tpgenie-and-having-an-external-tax-advisor/): When using TPGenie for creating local files for your MNE group entities, it could be that in some countries (for... - [What is the CbCR Survey?](https://intrapricing.com/blog/what-is-the-cbcr-survey/): Don’t waste your time on sending back and forth Excels and lots of emails! TPGenie transfer pricing software is equipped... - [Dutch Country-by-Country Reporting specifications v4.0](https://intrapricing.com/blog/dutch-country-by-country-reporting-specifications-v4-0/): On April 21th 2021 the Dutch Tax Authorities released an update of specifications in the Country-by-Country Reporting Guide, version 4.... - [Attribution of profits to a permanent establishment](https://intrapricing.com/blog/attribution-of-profits-to-a-permanent-establishment/): Transfer pricing with respect to permanent establishments deserves separate attention. Whereas the OECD guidelines are primarily aimed at transactions between... - [Public Country-by-Country Reporting](https://intrapricing.com/blog/public-country-by-country-reporting/): As of June 1, 2021, a new phenomenon came to stage: Public Country-by-Country Reporting. The key difference under this new... - [Transfer Pricing Basics: How to set the correct transfer price?](https://intrapricing.com/blog/transfer-pricing-basics-how-to-set-the-correct-transfer-price/): For a number of years now, tax authorities have been paying increasing attention to transfer pricing. But, how to set... - [Software update: IAM integration for TPGenie](https://intrapricing.com/blog/software-update-iam-integration-for-tpgenie/): TPGenie has been updated with Identity Access Management (IAM) features. IAM, also known as identity and access management (IAM or... - [What is operational transfer pricing?](https://intrapricing.com/blog/what-is-operational-transfer-pricing/): For many MNEs, transfer pricing is one of the major tax risks. This is because if an MNE and the... - [What is the arm’s length principle?](https://intrapricing.com/blog/what-is-the-arms-length-principle/): Multinationals carry out activities in various countries with the aim of making a profit. The shareholders of multinationals are interested... - [What is transfer pricing documentation?](https://intrapricing.com/blog/what-is-transfer-pricing-documentation/): In this article we will explain what transfer pricing documentation entails. First, we will explain why you need transfer pricing... - [Business restructurings and transfer pricing](https://intrapricing.com/blog/business-restructurings-and-transfer-pricing/): Multinational entities are able to optimise their profitability by restructuring functions, assets and risks. These are business restructurings in which... - [Adobe Sign API integration](https://intrapricing.com/blog/adobe-sign-api-integration/): Last months, we worked hard to integrate Adobe Sign capabilities into the TPGenie Intercompany Agreement Creation Module. The new integration... - [Intercompany agreements: the relevance explained](https://intrapricing.com/blog/intercompany-agreements-the-relevance-explained/): A multinational entity (MNE) has its companies and activities located in (several) different countries. These ‘group companies’ often provide each... - [Download free Transfer Pricing Local File template](https://intrapricing.com/blog/download-free-transfer-pricing-local-file-template/): A professionally written local file is the key ingredient of your transfer pricing documentation. Whether you’re a CFO, transfer pricing... - [How to create compliant transfer pricing documentation?](https://intrapricing.com/blog/how-to-create-compliant-transfer-pricing-documentation/): A common question for transfer pricing advisors from their clients is: “How do I create compliant transfer pricing documentation? ”.... - [Country-by-Country Reporting corrections](https://intrapricing.com/blog/country-by-country-reporting-corrections/): In case your group or client has updated Country-by-Country Reporting (CbCR) information, a CbCR correction should be made. A reason... - [Overview of CbCR tax portal per country](https://intrapricing.com/blog/overview-of-cbcr-tax-portal-per-country/): TPGenie has powerful Country-by-Country Reporting features and CbCr services. Apart from features such as CbC data gathering, risk analysis based... - [Compare Transfer Pricing software: static vs. dynamic documentation](https://intrapricing.com/blog/compare-transfer-pricing-software-static-vs-dynamic-documentation/): When you are looking for purchasing the best transfer pricing software for your company, there are many considerations in making... - [What if CbCR conversion software didn't exist? Manual steps to create a CbCR filing.](https://intrapricing.com/blog/what-if-cbcr-conversion-software-didnt-exist-manual-steps-to-create-a-cbcr-filing/): If you are responsible for performing the Country-by-Country Reporting for your group or as a tax advisor for your clients,... - [Translate your transfer pricing documentation automatically](https://intrapricing.com/blog/translate-your-transfer-pricing-documentation-automatically/): In many countries it is required to submit your Transfer Pricing documentation in a local language. This article provides you... - [Reporting Fiscal Unity and Local figures](https://intrapricing.com/blog/reporting-fiscal-unity-and-local-figures/): TPGenie was already for years equipped with functionality that allows reporting a fiscal unity (fiscale eenheid in Dutch) accurately. In... - [TPGenie Users Day 2020](https://intrapricing.com/blog/tpgenie-users-day-2020/): This week we organised TPGenie Users Day 2020 together with H&M. With our MNE key users we discussed the future... - [Transfer pricing benchmarking software released](https://intrapricing.com/blog/transfer-pricing-benchmarking-software-released/): We have worked hard to develop a new software product that takes the complicated process of performing an economic analysis... - [Belastingdienst brengt versie 2.0 van de handleiding Gegevensaanlevering van landenrapporten uit](https://intrapricing.com/blog/belastingdienst-brengt-versie-2-0-van-de-handleiding-gegevensaanlevering-van-landenrapporten-uit/): Vanaf 4 juli 2018 moeten bij de Belastingdienst aangeleverde landenrapporten (Country-by-Country reporting / CbCR) voldoen aan de nieuwste versie 2.... - [Create and Manage your Intercompany Agreements](https://intrapricing.com/blog/intercompany-agreements-module/): Multinationals are obliged to be in the possession of a list of ICAs (intercompany agreements), which serve as a supporting... - [Submit your Country-by-Country Reporting to the Dutch tax authorities (Belastingdienst)](https://intrapricing.com/blog/submit-your-country-by-country-reporting-to-the-dutch-tax-authorities-belastingdienst/): TPGenie is now ready for the electronic transmission of your BEPS Action 13 Country-by-Country reporting XML file to the tax... - [Country-by-Country Reporting (CbCR) Excel to XML conversion Tool](https://intrapricing.com/blog/country-by-country-reporting-cbcr-excel-to-xml-conversion-tool/): Our software solution TPGenie is ready for generating your BEPS Action 13 Country-by-Country reporting in the XML format according to... - [Tax Technology Event 2017 – From ‘Staying Out Of Trouble’ To ‘Being In Control’](https://intrapricing.com/blog/tax-technology-event-2017-from-staying-out-of-trouble-to-being-in-control/): Thursday, 7 September 2017 Time: 9. 00am – 4. 00pm Amsterdam (CET) Venue: Marriott Courtyard Amsterdam Airport Hotel In the... - [OECD releases peer review documents for assessment of BEPS minimum standards (Actions 5 and 13)](https://intrapricing.com/blog/oecd-releases-peer-review-documents-for-assessment-of-beps-minimum-standards-actions-5-and-13/): On February 1, 2017, the OECD released key documents, approved by the Inclusive Framework on BEPS, which will form the... --- # # Detailed Content ## Pages Transfer Pricing Services Transfer Pricing Services Powered by TPGenie At Intra Pricing Solutions, we deliver comprehensive transfer pricing services that combine deep technical expertise with powerful automation software. Our in-house economists and tax professionals prepare transfer pricing documentation, perform functional analyses, conduct benchmarking studies, and create transfer pricing policies that ensure global compliance. Supported by our proprietary TPGenie software, we help multinational groups prepare Local Files, Master Files, and CbCR reports that meet both OECD Transfer Pricing Guidelines and local country requirements. Whether you need managed transfer pricing documentation, transfer pricing benchmarking, or TP policy design, we offer scalable solutions trusted by international clients. Our Core Transfer Pricing Services 1. Transfer Pricing Documentation and Compliance We prepare complete, audit-ready transfer pricing documentation in line with the OECD BEPS Action 13 framework. Using TPGenie’s documentation automation, we streamline the creation of Local Files, Master Files, and Country-by-Country (CbCR) reports. We deliver: Master File and Local File reports aligned with OECD and local TP legislation CbCR XML generation and submission via official portals Integrated financial data management within TPGenie Consistent reporting across multiple jurisdictions Automated tracking of deadlines and compliance alerts Our goal is to make transfer pricing compliance efficient, transparent, and fully traceable. 2. Functional Analysis and Intercompany Interviews Our experts conduct detailed functional analyses through structured intercompany interviews. We assess functions, assets, and risks to classify entities accurately and define each company’s role within your global value chain. This service includes: In-depth interviews with key operational teams Identification of DEMPE... --- Manage global transfer pricing compliance with TPGenie's Compliance Tracker. Customise country-specific tax requirements, automate risk assessments, and track deadlines for Master Files, Local Files, CbCR, and more. Stay compliant with yearly updates and Pillar Two insights. The Compliance Tracker is designed to provide an overview of transfer pricing and tax-related obligations across multiple jurisdictions. With over 75 tax and transfer pricing related data points, this module provides an exhaustive, up-to-date overview of TP requirements for every country worldwide, helping MNEs and Tax advisors stay on top of their compliance obligations.   Key Features Global Coverage: The Compliance Tracker includes data for all countries, covering numerous jurisdiction-specific Transfer Pricing and tax-related requirements. This includes essential dates, URLs to local tax authority portals, and country-specific references. The module is updated yearly. Customisable Data: While the Tracker uses generic data from third-party sources, it offers the flexibility to customise this information based on your group's specific requirements. This ensures that your Transfer Pricing policies are accurately reflected. Risk Assessment: The module includes an automated risk assessment for each country based on your group’s activities, helping you identify potential compliance risks early. Yearly View: Starting from FY 2019, the Tracker allows you to view compliance data for any given fiscal year, enabling historical and forward-looking planning. Customisation & Group-Specific Data One of the standout features of the Compliance Tracker is its flexibility. Users can override the default country-specific data with their own group’s information. This includes custom deadlines, local filing requirements, and specific statuses... --- Manage and reconcile your global transfer pricing data with TPGenie's Reconciliation Module. Designed for Transfer Pricing managers, this module allows you to review financial data across multiple entities, identify discrepancies, and ensure compliance. With advanced filtering, real-time currency conversion, and Excel export, you can streamline the reconciliation process and maintain a clear overview of your transfer pricing position. The Reconciliation Module in TPGenie is designed for Transfer Pricing managers to perform transfer pricing reconciliations and review financial data for multiple entities with ease and precision. This module provides companies with the ability to analyse and test their transfer pricing models based on actual financial performance across their global operations. By doing so, companies gain a clear understanding of their transfer pricing position, allowing them to make adjustments either retrospectively or proactively, ensuring compliance and optimisation.  Key Features Review Financial Data Across Entities:TP managers can evaluate financial data for multiple legal entities through an intuitive Data Review Dashboard. This enables real-time analysis of transfer pricing positions, ensuring that all entities are aligned. Financial Reconciliations:Compare seller and purchaser transaction values across entities. The module helps identify discrepancies in transaction amounts, making it easier to reconcile financials and take corrective action if needed. Advanced Filtering and Customisable Views:The module offers powerful filtering options, including Boolean searches, allowing users to isolate specific transactions or discrepancies. The data is displayed in a pivot table format with configurable columns, and users can create multiple setups for various analyses. Currency Conversion:Quickly convert financial amounts into your chosen... --- Experience the future of transfer pricing with TP Copilot, an AI-Powered validation Module. TP Copilot integrated with TPGenie enhances transfer pricing by automating compliance tasks, identifying discrepancies, and providing real-time recommendations based on OECD guidelines and local legislation. Eliminate errors, and ensure compliance with cutting-edge AI technology. From detecting inconsistencies to cross-checking data and correcting grammar, our solution reduces biases, blind spots, and helps you stay ahead.     Discover the future of transfer pricing with TP Copilot our AI-Powered Transfer Pricing Module – a revolutionary tool that checks compliance with OECD and local regulations for both Local and Master files, and cross-checks your data for consistency and accuracy across all your entities. With features like real-time data validation, automatic error detection, and AI-driven recommendations, this module reduces your workload, eliminates biases, and helps you catch blind spots before they become issues. Features Cross-Checks with External Files Beyond reviewing Local and Master Files, TP Copilot automatically validates your transfer pricing documentation against externally generated deliverables. This ensures that all reports, forms, and agreements align seamlessly across your compliance landscape. Key cross-checks include: Local File ↔ Country-by-Country Report (CbCR): Ensures consistency in revenues, FTEs, and business unit reporting. Local File ↔ TP Forms: Verifies that transactional and financial data match regulatory submissions. Local File ↔ Intercompany Agreements & APAs: Confirms that described transactions align with signed agreements and approved advance pricing arrangements. Local File ↔ Appendices & Supporting Documents: Detects mismatches in financial data, functional analysis, and entity details. Year-on-Year Comparisons:... --- ProductsModulesBenchmarking Database The Benchmarking Database takes the complicated process of performing an economic analysis off your hands: it provides high quality benchmarking studies in few easy steps. It simplifies transfer pricing analyses, including profit and transaction-based analyses. Benchmarking Database The Benchmarking Database takes the complicated process of performing an economic analysis off your hands: it provides high quality benchmarking studies in few easy steps. It simplifies transfer pricing analyses, including profit and transaction-based analyses. Pillar Two Navigate the complexities of global minimum tax with our innovative tool. Designed for multinational enterprises and tax advisors, our module aligns with the latest international tax framework, ensuring compliance and effective tax rate management. Pillar Two Navigate the complexities of global minimum tax with our innovative tool. Designed for multinational enterprises and tax advisors, our module aligns with the latest international tax framework, ensuring compliance and effective tax rate management. Transfer Pricing Benchmarking AI Artificial Intelligence (A. I. ) tools for speeding up your benchmarking process, crawling and translating company websites. Transfer Pricing Benchmarking AI Artificial Intelligence (A. I. ) tools for speeding up your benchmarking process, crawling and translating company websites. Intercompany Agreements database Intercompany agreement management repository that provides numerous of functionalities for managing your intercompany agreements. Easily show all missing agreements and map potential available agreements automatically. Intercompany Agreements database Intercompany agreement management repository that provides numerous of functionalities for managing your intercompany agreements. Easily show all missing agreements and map potential available agreements automatically. Create and manage Agreements Intercompany Agreement... --- Explore the financial benefits of integrating TPGenie Benchmarking AI into your transfer pricing benchmarking process through our cost savings calculator. Our tool provides a straightforward comparison between the conventional manual approach and the streamlined efficiency achieved with TPGenie Benchmarking AI. The below form calculates cost savings by comparing manual benchmarking processes with the adoption of TPGenie Benchmarking AI. Please input your details about annual benchmarking activities and costs, and the form calculates the total hours and expenses for manual work versus the savings achieved with TPGenie Benchmarking AI. This calculator exemplifies the substantial efficiency and financial advantages of adopting TPGenie Benchmarking AI for your transfer pricing benchmarking tasks. 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","groupingsymbol":"","readonly":true,"currency":false,"noEvalIfManual":true,"formatDynamically":false,"dynamicEval":true,"hidefield":false,"validate":false,"fBuild":{},"parent":""}],{"0":{"title":"Cost Savings Calculator","description":"\n","formlayout":"top_aligned","formtemplate":"cp_cff_13","titletag":"H2","textalign":"default","headertextcolor":"","evalequations":1,"evalequations_delay":0,"evalequationsevent":2,"direction":"ltr","loading_animation":0,"autocomplete":1,"persistence":0,"animate_form":0,"animation_effect":"fade","customstyles":""},"formid":"cp_calculatedfieldsf_pform_1"}]; --- Navigate the complexities of global minimum tax with our innovative tool. Designed for multinational enterprises and tax advisors, our module aligns with the latest international tax framework, ensuring compliance and effective tax rate management. Access essential tools like the Transitional Safe Harbour Calculation Sheet and a comprehensive Regulations Library, making tax assessment and risk control more efficient and transparent. Pillar Two (GloBE) module in TPGenie TPGenie has already offered solutions under the umbrella of BEPS - automated Transfer Pricing documentation tool as well as Country-by-Country Reporting Software. In its ambition to further expand the modules along with the development of the international regulations, Pillar Two (GloBE) model has been added to the scope of its offering. Pillar Two (GloBE) module is a user-friendly tool that will consist of the following parts: Pillar Two Transitional Safe Harbour Calculation Sheet (planned go live: January 2024) - a calculator of the three transitional safe harbour tests per jurisdiction. Based on the outcome of the exercise, it would be possible to conclude e. g. what is the risk exposure of MNE with regard to Pillar Two rules or for which countries the full GloBE calculations might need to be further prepared; The sheet will be exportable in Excel so it would be easier to share the outcome of the investigation with the interested parties (e. g. external auditors) in order to prove control over Pillar Two risks; Pillar Two Regulations Library (planned go live: January 2024) - the search engine with access to relevant... --- Artificial Intelligence (A. I. ) tools for speeding up your benchmarking process, crawling and translating company websites. Introducing TPGenie's AI tools, designed to elevate your benchmarking workflow seamlessly. TPGenie Benchmark AI Revolutionise your transfer pricing benchmarking with precision. Our AI-driven solution effortlessly converts and translates company websites into structured text, reducing manual workload through automatic comparisons with your tested party. Benefit from insightful pattern analysis, gaining a deeper understanding of your search results. Precision is paramount with Benchmark AI, which automatically calculates arm's length range for your PLIs. Captures comprehensive data via website screenshot collection. State-of-the-art document templates which enable you to simplify the creation of automated benchmarking writeups. This feature enables you to refine your search results with enhanced precision, focusing on comparing business activities across different entities. By inputting specific business activities and keywords, TPGenie will assess the relevance and comparability of search results within your defined scope. You can use our Benchmark AI features to automatically crawl & retrieve detailed company information. You can achieve a 95% accuracy rate in automatically accepting or rejecting your search results with the use of TPGenie Benchmarking AI!       AI Writing Assistant Boost productivity effortlessly. Our AI Writing Assistant streamlines local file creation. Craft articulate test cases effortlessly with context-aware suggestions. Experience fluid collaboration as the AI refines language, enhancing clarity and conciseness. TPGenie's AI tools empower experts like you to navigate complexities efficiently. Enhance precision, elevate collaboration, and unlock unparalleled insights. Revolutionize your experience with TPGenie. How to... --- Customer Success StorySince 2021 Vanderlande Industries is using TPGenie Enterprise, including inter-company Agreement Database, currency conversion, CbCR and translation modules. We’ve been pioneering a world of possibilities to bring surfaces to life for well over 200 years. As experts in making coatings, there’s a good chance you’re only ever a few meters away from one of our products. Our world class portfolio of brands – including Dulux, International, Sikkens and Interpon – is trusted by customers around the globe. We’re active in more than 150 countries and have set our sights on becoming the global industry leader. It’s what you’d expect from the most sustainable paints company, which has been inventing the future for more than two centuries. Visit websiteThe challenge Previously Vanderlande Industries had a very manual process which required more time and efforts on data gathering and manual preparation of the Transfer Pricing documentation. This was both inefficient and error-prone and required a lot of labor-intensive updating of information and validating the resulting reports. The solution Through TPGenie the aim was to integrate (financial) data in an efficient manner and prepare the Transfer Pricing documentation in a more efficient, automated manner based on a fixed workflow and built-in validations and audit trail. Besides generating the TP local and master files, the integrated solution of TPGenie should enable us to manage our intercompany TP agreements, convert currencies, translate the reports to other languages and generate the country-by-country-report. The results TPGenie was implemented in a short timeframe with hands-on support... --- First name (*) Last name (*) Country (*) ---AfghanistanÅland IslandsAlbaniaAlgeriaAmerican SamoaAndorraAngolaAnguillaAntarcticaAntigua And BarbudaArgentinaArmeniaArubaAustraliaAustriaAzerbaijanBahamasBahrainBangladeshBarbadosBelarusBelgiumBelizeBeninBermudaBhutanBoliviaBonaireBosnia & HerzegovinaBotswanaBouvet IslandBrazilBritish Indian Ocean TerritoryBrunei DarussalamBulgariaBurkina FasoBurundiCabo VerdeCambodiaCameroonCanadaCayman IslandsCentral African RepublicChadChileChinaChristmas IslandCocos (Keeling) IslandsColombiaComorosCook IslandsCosta RicaCôte d'IvoireCroatiaCubaCuracaoCyprusCzech RepublicDenmarkDjiboutiDominicaDominican RepublicEcuadorEgyptEl SalvadorEquatorial GuineaEritreaEstoniaEthiopiaFaroe IslandsFijiFinlandFranceFrench GuianaFrench PolynesiaFrench Southern TerritoriesGabonGambiaGeorgiaGermanyGhanaGibraltarGreeceGreenlandGrenadaGuadeloupeGuamGuatemalaGuernseyGuineaGuinea-bissauGuyanaHaitiHeard Island And McDonald IslandsHondurasHong KongHungaryIcelandIndiaIndonesiaIranIraqIrelandIsle Of ManIsraelItalyJamaicaJapanJerseyJordanKazakhstanKenyaKiribatiKoreaKuwaitKyrgyzstanLao People's Democratic RepublicLatviaLebanonLesothoLiberiaLibyaLiechtensteinLithuaniaLuxembourgMacaoMacedoniaMadagascarMalawiMalaysiaMaldivesMaliMaltaMarshall IslandsMartiniqueMauritaniaMauritiusMayotteMexicoMicronesiaMoldovaMonacoMongoliaMontenegroMontserratMoroccoMozambiqueMyanmarNamibiaNauruNepalNetherlandsNew CaledoniaNew ZealandNicaraguaNigerNigeriaNiueNorfolk IslandNorthern Mariana IslandsNorwayOmanPakistanPalauPalestinian TerritoryPanamaPapua New GuineaParaguayPeruPhilippinesPitcairnPolandPortugalPuerto RicoQatarReunionRomaniaRussian FederationRwandaSaint BarthélemySaint Kitts And NevisSaint LuciaSaint Pierre And MiquelonSaint Vincent And The GrenadinesSamoaSan MarinoSao Tome and PrincipeSaudi ArabiaSenegalSerbiaSeychellesSierra LeoneSingaporeSlovakiaSloveniaSolomon IslandsSomaliaSouth AfricaSouth Georgia And The South Sandwich IslandsSouth SudanSpainSri LankaSudanSurinameSvalbard And Jan MayenSwedenSwitzerlandSyrian Arab RepublicTaiwanTajikistanTanzania, United Republic OfThailandTimor-LesteTogoTokelauTongaTrinidad And TobagoTunisiaTurkeyTurkmenistanTurks And Caicos IslandsTuvaluUgandaUkraineUnited Arab EmiratesUnited KingdomUnited StatesUnited States Minor Outlying IslandsUruguayUzbekistanVanuatuVenezuelaViet NamVirgin Islands (British)Virgin Islands (US)Wallis And FutunaWestern SaharaYemenZambiaZimbabwe Business E-mail (*) Company (*) Website I am (*) ---representing a Multinational Enterpriserepresenting a Local Entitya Tax Advisor serving 0-5 clientsa Tax Advisor serving more than 5 clientsOther I am interested in (*) TPGenie BusinessTPGenie BasicTPGenie EnterpriseBenchmarking ModuleCreating and managing Inter-Company AgreementsLegal Entity ManagementCountry-by-Country Reporting moduleCurrency Conversion ModuleTranslation ModuleTransfer Pricing AI toolsBecoming Partner/Reseller Message Please leave this field empty. --- The Legal Entity Management (LEM) Module is an easy to use cloud solution that enables you to manage your legal entity governance and compliance in TPGenie. The Legal Entity Management module is useful to provide scrutiny and transparency, and helps to manage complexity and risk of uncertain regulatory changes and associated costs for all legal entities within your organisation. It gives better control of data and insight into the entity compliance process. Together with your (legal-) team you have online access to your corporate library. You can manage your entities, shares, mergers and acquisitions in a fast growing environment, and you can keep track of shareholders, directors, and authorised signatories. In a few easy steps you can create entity reports such as UBO documentation and number of diagrams and organisation charts, such as FTE macro functions, organigrams and entity ownership. Legal Entity Management Features Legal Entity Management & Overview: Access to corporate entity information anywhere, anytime; Documentation & Entity Attachments: create and manage entity documentation such as UBO information and more; Legal Ownership Structure & Orgcharts: Automatically generate OrgCharts and diagrams based on ownership; Map: Filter and restructure your group on the world map; Person overview: Overview of people and authorisations; SaaS cloud database: Efficiently manage the data of legal entities via a secure online corporate database. Back to ModulesContact UsYour guide in the world of Transfer PricingHerengracht 301015 BL, Amsterdam+31 20 422 8885linkedinfacebookyoutubeDrop us a message --- Customer Success StorySince 2014 H&M is using TPGenie Enterprise and is development partner of TPGenie. H&M Group is a family of brands and businesses, driven by the desire to make great design available to everyone, in a more sustainable way. We offer fashion, design and services that inspire and enable people to express their style while making it easier to live more circular. We offer fashion and quality at the best price in a more sustainable way. Visit websiteThe challenge Whether to prepare the document internally or with the help of an external professional. Whether the TP documentation prepared on a global basis complies with the requirements in each country. Whether the cost of creating and maintaining the documentation offsets the risks associated with the transactions. The solution TPGenie is software is the one-stop solution for Hennes & Maurits for creating & managing Transfer Pricing documentation, including Local Files, Master Files, Benchmarks, Inter-Company Agreements, Country-by-Country Reportings. Additionally a Legal Entity Management module is developed. The module is useful to provide scrutiny and transparency, and helps to manage complexity and risk, giving better control of data and insight into the entity compliance process. The results TPGenie helps H&M group to efficiently create, update and manage our transfer pricing documentation in line with BEPS 13 action. TPGenie also guides us through TP planning, risk management, and control. "TPGenie; what would our transfer pricing function be without it! "Back to overviewConsumer Retail Industry H&M Group is a family of brands and businesses, driven... --- We protect your data with the highest security measures We protect your transfer pricing data with the highest security measures TPGenie runs on our secured TPGenie Transfer Pricing Cloud platform. More than 2800 users worldwide use TPGenie to ensure the confidentiality and security of their transfer pricing data. We take security seriously. IS0 27001 Intra Pricing Solutions B. V. and it's secured TPGenie Transfer Pricing Cloud platform is ISO 27001 certified as of December 2022. Certificates can be provided upon request. Data encryption All data transferred between TPGenie users and the TPGenie cloud infrastructure is encrypted using state-of-the-art TLS encryption. Data at rest is encrypted on our servers. We regularly review the cipher suites used and deprecate those which may become insecure in the future. Data storage All TPGenie clients have their separate secured environment on the TPGenie Transfer Pricing Cloud platform. The client environments are stored segregated on the cloud server for extra security, which prevents mingling data between clients. Data centers The TPGenie transfer pricing cloud ecosystem is hosted and operated in a co-location in data centers in The Netherlands with an ISO 27001 certified data center operator, which is audited regularly. Our servers are protected by the highest physical means and only selected Intra Pricing Solutions employees with operational tasks have access to them. Reliability All TPGenie networks are redundant and secured by automatic failover mechanisms to ensure trouble-free service, with a measured uptime of 99. 99% in the last 12 months and 0% downtime in the... --- Customer Success Story Since 2017 Bobst is using TPGenie Enterprise. BOBST serves the packaging industry as one of the world’s leading suppliers of substrate processing, printing and converting equipment and services for the label, flexible packaging, folding carton and corrugated sectors. BOBST is shaping a new reality where connectivity, digitalization, automation and sustainability are the cornerstones of packaging production. BOBST continues to deliver best-in-class machines, and is now adding intelligence, software capabilities and cloud-based platforms, to make packaging production better than ever. Visit website The challenge We were facing all the challenges of a decentralized organization with little integration: heavy dependence on external tax advisors to produce our Local Files, high related costs, absence of synergies and risk of inconsistencies and duplications. On top of that, we did not have a one-stop repository for all our Transfer Pricing Documentation. The solution Since 2017, we use Local File, Country-by-Country Reporting, Intercompany Agreement Database, Agreement Lab and Review report modules. The software is easy to implement and friendly to use, whether you have an administrator or a user role. The results In line with our new vision for the industry, TPGenie enables us to manage the whole end-to-end process and integrate all the components of our transfer pricing documentation in the most efficient, cost-effective and consistent way. TPGenie is the cornerstone of our TP compliance cycle but also brings our Tax function value and visibility towards our business leaders. TPGenie really helps to up your Transfer Pricing documentation game. It is more... --- Customer Success Story Since 2019 Nouryon is using TPGenie Enterprise. Nouryon is a global specialty chemicals leader. Markets worldwide rely on our essential chemistry in the manufacture of everyday products such as paper, plastics, building materials, food, pharmaceuticals and personal care items. We have about 10,000 employees and operate in over 80 countries around the world. Building on our nearly 400-year history, we have established a world-class business and built strong partnerships with our customers. Visit website The challenge Pre the implementation of TPGenie, the preparation of Transfer Pricing documentation was a manual, decentralized process involving many people within the organization and external advisors. Implementing changes to all documents on an annual basis and monitoring the completeness of the compliance was a time-consuming process. The solution We utilize the TPGenie Enterprise license, CBCR, Intercompany Agreements database and currency conversion modules. The tool is user friendly for the local finance community and there is a good level of standardization and automation. The results We have been using the tool for a few years and this has helped us to be compliant with our TP documentation requirements in an efficient manner. The processing of changes to templates on an annual basis and the monitoring of the compliance status can be done easily. The Intrapricing Solutions team continues to innovate and add functionality to the tool. Although a small team, the service and response time is always good. Keep up the good work. Back to overviewSpecialty Chemicals Nouryon is a global specialty chemicals... --- Customer Success StoryBasefirma is using TPGenie Business since 2019. Basefirma is a team of experienced international economists, MBA’s, tax lawyers and accountants, covering all transfer pricing needs and related international tax issues. We are highly specialized in our field, and offer efficient, top quality, while guaranteeing personalized, on-the-spot attention. We have a physical presence in all major markets and indeed we serve clients all over the world, offering you tailor-made advice and products, focused on what your company needs. Visit websiteThe challenge Tackling global projects covering multiple jurisdictions, with different regulations, languages, and deadlines always pose a challenge. Moreover, managing flows of information from various sources, compiled under inconsistent criteria makes the compliance process more difficult than it should. The solution TPGenie allows us to undertake large scale international projects without losing central coordination, overview, consistency, and quality control. The data review module offers a quick insight in how each company books the intragroup flows. The survey process is truly clear and auditable and allows to track every change if needed. The currency conversion module comes handy to reconcile diverse sources of information. Document templates are extremely flexible, with the use of conditional rules and loops. In general, the tool is constantly updated to address both regulatory changes and customer feedback. The results The output of TPGenie is a professional grade set of documentation, including Master File, Local Files, CbCr, agreements, etc. Creating an initial set of documents with TPGenie is faster than using traditional tools. Scaling and maintaining existing... --- Customer Success StoryTPA Global is using TPGenie Business including CbCR Modules since 2016. TPA Global is a consulting firm, delivering solutions in the area of tax & transfer pricing, digital transformation and dispute resolution. The company’s focus is on challenges corporates are faced with on the cross-roads between finance, tax and IT. The company aims at de-risking the client’s tax line in a practical and sustainable manner. Visit websiteThe challenge We had significantly varying file styles, formats and contents. In addition, when creating multiple files for the client, lots of time was spent on copy-pasting and checking for wrongly pasted data. The solution We use TPGenie Business as TP doc tool and the CbCR module – to create 3-tier documentation for our clients in an efficient and compliant manner. We also use the Transfer Pricing Guide to stay on top the deadlines and requirements. The results TPA Global local files are now standard and nicely formatted. We also spend much less time on preparation of large amounts of reports for a specific client. Further, we use TP Genie as a communication tool with clients as they can track progress and review files within the system. "TPGenie is the practical and efficient tool that we recommend to both consultants and multinationals. "Back to overviewConsulting TPA Global is a consulting firm, delivering solutions in the area of tax & transfer pricing, digital transformation and dispute resolution. The company’s focus is on challenges corporates are faced with on the cross-roads between finance, tax... --- Customer Success Story Since 2017 the Triumph Group is using TPGenie Enterprise. It all began in a barn: The transformation of the Triumph Group from a tiny Southern German corset factory back in 1886 into one of the world’s leading manufacturers of lingerie and underwear is a global success story. The Triumph Group today enjoys a presence in over 120 countries all across the world. For its brands Triumph and sloggi, the company develops, produces and sells underwear, lingerie, sleepwear and swimwear, fusing excellent quality in workmanship, unrivalled fit and the latest in fashionable design. Visit websiteThe challenge Before Triumph adopted TPGenie, the group incurred substantial annual costs of engaging external service providers to prepare local TP documentation. Another challenge which the company faced was a lack of central control over how the TP policy was communicated in the local TP documentation, because the process was largely driven by local Finance personnel in conjunction with local tax advisers. The solution We use the TPGenie modules for preparing local TP Reports, for Country-by-Country Reporting, and for Intercompany Agreements. The system works very well for us – for example, the Report module enables us to combine local input from the Finance teams, with centrally-defined input and economic analyses. The Country-by-Country Reporting module works very smoothly for us, and the Intercompany Agreements module is very useful. The results Triumph has made significant improvements in our TP compliance in recent months, and we are now up-to-date with our local TP compliance obligations. Now that... --- Customer Success StorySince 2014 AkzoNobel is using TPGenie Enterprise. We’ve been pioneering a world of possibilities to bring surfaces to life for well over 200 years. As experts in making coatings, there’s a good chance you’re only ever a few meters away from one of our products. Our world class portfolio of brands – including Dulux, International, Sikkens and Interpon – is trusted by customers around the globe. We’re active in more than 150 countries and have set our sights on becoming the global industry leader. It’s what you’d expect from the most sustainable paints company, which has been inventing the future for more than two centuries. Visit websiteThe challenge Prior to implementing TPGenie we struggled to find a consistent and efficient approach to preparing local transfer files on a global basis. We were suffering from challenging processes to share and delegate the documents along with tasks. In addition, we incurred high costs for services provided by external consultants. Bearing in mind that the AkzoNobel group is performing activities in various regions, differentiated by scope of reporting obligations, coordination of the whole process was a key issue. The solution In AkzoNobel, we utilize the TPGenie Enterprise license along with the BEPS compliant Country-by-Country reporting module. Additionally, we deploy tailored adjustment options which include the intercompany agreement database and the data evaluation and currency conversion modules. Recently we started to use the translation module and the Transfer Pricing Guide. TPGenie is a very user-friendly tool. From the user perspective each step... --- TPGenie API Reference As a developer, you can build a variety of integrations with the TPGenie API. The integrations allow you to control TPGenie from external applications. The TPGenie APIs can be used to: Poll for status updates Create and manage environments Create and manage financial years Create and manage users More to follow... TPGenie's APIs use HTTP verbs and a RESTful endpoint structure. An access key is used as the API Authorization framework. Request payloads can be both provided as GET and POST requests and responses are formatted as JSON, using UTF-8 encoding and URL encoded values. Docs & References The API reference guide is available for clients only. In order to use the API, you need to first sign up. Sign up for the TPGenie API Use APIs from TPGenie to create custom applications for your teams, partners, and customers. Sign up for a license to get access to: Access to the TPGenie API Access to the documentation Testing environment Production environment(s) For a demo or signing up, please send us a message.     --- Customer Success StorySince 2015 Wolter Koops Group uses TPGenie Enterprise. Wolter Koops operates in the international controlled-temperature transport and logistics market. The area of operation is Europe. Wolter Koops provides logistic services encompassing transport, distribution, crossdocking and warehousing, all in an integrated cold-chain. Wolter Koops provides its services in segments of food, dairy, flowers, plants, fruit and vegetables. Wolter Koops offers customised services and flexible solutions. Wolter Koops' strength lies in our integrated approach to the clients' logistics needs. Visit websiteThe challenge Before the TPGenie software was used, the TP files were built up using Word documents. Maintaining an overview, implementing changes to all documents, the transition to a new fiscal year, and monitoring the completeness of the files was a time-consuming process. The solution TPGenie, Intercompany agreements and the Agreements Lab Modules are used. The software shows a clear process in subsequent steps to build a local and master file. Through the integration of the Agreement Lab, internal contracts are directly linked to the correct Transaction profile. Missing an essential part in the report is thus kept to a minimum. The results The TPGenie software allows a complete local and master file to be created within the Wolter Koops Group that complies with the requirements of the Transfer Price regulations and can be used for audits performed by the tax authorities in the various countries. "TPGenie gives us the tool to meet the requirements of Transfer Pricing regulations in an efficient way. "Back to overviewTransport & Logistics Wolter Koops... --- Transfer Pricing BlogContact UsYour guide in the world of Transfer PricingHerengracht 301015 BL, Amsterdam+31 20 422 8885linkedinfacebookyoutubeDrop us a message --- TPGenie Partner Program The TPGenie partner program rewards you with a range of benefits that you can tailor to your own practice goals. We’ve created it to make you even more successful – no matter what success means to you. Enterprise clients increasingly engage consultancies with the expectation of being equipped to solve the challenges of tomorrow, not just today. Differentiate your value proposition and leverage TPGenie’s proven impact to win new business. Empower your clients with TPGenie as a vehicle to forge deeper and longer-term relationships. As a tax advisor or independent transfer pricing specialist, you can become a TPGenie partner. You will immediately gain access to software, education, and marketing support – not to mention the value you can pass on to your clients. We’ll help you grow to earn even more. Boost your TPGenie Partner status Stick with the core activities or add on a few layers of extras – it’s up to you and your practice. The more clients you have on TPGenie, the more you’ll gain for your own business. It isn’t all about big numbers at TPGenie – it’s about acknowledging our relationship too. That’s why you’ll see a special endorsement in our partner program that will award you a different status based on your level of expertise. Showcase your achievements Are you excellent at retaining clients? Got a lot of experience with TPGenie? We award TPGenie status to celebrate your milestones and expertise and help promote your achievements to potential clients. Attract new... --- Integrate TPGenie into your company's systems and build powerful apps. Use APIs to connect your applications to TPGenie. Developers Build, launch and grow your software with TPGenie Many cloud integrations built by businesses or advisors can integrate with TPGenie. Partner with us, and we’ll make sure they find yours. Grow your business Reaching businesses is hard. TPGenie already has hundreds of subscribers worldwide. Building to our API creates an opportunity of new revenue streams and global channel to market for your software. Here you can find our current integrations. Deliver for your customers Connect to TPGenie to create a powerful, end-to-end solution in the cloud for your customers. We’ll take care of the Transfer Pricing documentation and compliance end, so you can focus on the needs of the customers in any additional features. Get started easily TPGenie was the first cloud-only all-in-one Transfer Pricing Compliance software. We’ve been investing in our platform, resources, documentation and team for over 10 years, so you can get started quickly. And we’re really nice to work with! Contact UsYour guide in the world of Transfer PricingHerengracht 301015 BL, Amsterdam+31 20 422 8885linkedinfacebookyoutubeDrop us a message --- Customer Success StorySince 2013 Ewals Cargo Care uses TPGenie Enterprise. In 1906, Alfons Ewals founded Ewals with a horse, a cart and a lot of ambition. Over a century later, the 4th Ewals generation proudly carries on his legacy. Today, Ewals Cargo Care creates unconventional logistics products by combining shipments by road, rail and short-sea to create the very best multimodal combination for your cargo. Visit websiteThe challenge Creating a compliant transfer pricing document for each of the Ewals Group entities. Whilst also standardizing the transfer pricing documentation for the 32 entities across 15 countries for the Ewals Group. Some of the 15 countries are very strict when it comes to the transfer pricing documentation. The solution Using an application specifically designed for creating transfer pricing documentation, with an easy yearly step-by-step process. The solution for the Ewals Group is TPGenie, it provides both an easy to maintain transfer pricing document creation process and a great way to standardize these documents across the Group with the possibility of adding country specific details. The results Within 1 month each year all company data is prepared and loaded into the tool, verified by financial and business controllers and thus the documents are created. What used to be done by an external company/partner we can now easily create and maintain the transfer pricing documents and maintain compliant within all 15 countries. “Oh, this makes it very simple, doesn’t it? ! ” “Wow, that was easy, I thought it would take us at least... --- See how TPGenie increases efficiency and reduces costs. A selection of our customers using TPGenie Transfer Pricing documentation solution for yearsLearn how Triumph reduced substantial annual costs of engaging external service providers by using TPGenie Enterprise.   TPGenie supports us to get proficient at resource efficiency and meet local transfer pricing documentation requirements. TPGenie allows BaseFirma to tackle large scale international projects without losing central coordination, overview, consistency, and quality control.   Learn how the implementation of TPGenie in a short timeframe with hands-on support from the Intra Pricing Solutions team enabled Vanderlande to manage and coordinate the transfer pricing documentation process inhouse. Achieving great comfort by rolling-out TPGenie as the central global tool for the TP compliance process. TPA Global uses TPGenie Business and the CbCR module as a TP doc tool to create 3-tier documentation.   Since 2014 Hennes & Mauritz is using TPGenie in a centralised way for Legal Entity Management, and for creating Transfer Pricing documentation and creating and managing their Inter-company agreements. H&M is development partner of Intra Pricing Solutions.   The TPGenie software allows a complete local and master file to be created for each entity in the Wolter Koops Group. Creating a compliant transfer pricing document for each of the Ewals Group entities. Whilst also standardizing the transfer pricing documentation for the 32 entities across 15 countries for the Ewals Group. The Intra Pricing Solutions team has become a true partner of our Tax transformation and TPGenie keeps BOBST ahead of the game.... --- Connect dashboards, identity providers, finance, and other business critical applications to TPGenie. Below you find an overview of current integrations that work together with TPGenie. Adobe Sign Adobe Sign is a cloud-based e-signature service that allows the user to send, sign, track, and manage signature processes using a browser or mobile device. It is part of the Adobe Document Cloud suite of services. Apple iCloud Calendar Track calendar events. ChatGPT TPGenie has made a significant leap towards automation and artificial intelligence by seamlessly incorporating ChatGPT – a state-of-the-art natural language generation system. Citrix Workspace Citrix Workspace integration including VPN and SSO services. DeepL Translation services. Google Calendar Track calendar events. Google Maps Location services with Google Maps. Intercompany Software Cloud-based Transfer Pricing Operations solution that improves your Transfer Pricing governance, financial data and calculations audit trail, and operational excellence and process efficiency. MessageBird APIs, tools, customer support software, and a global connectivity network to elevate business to customer relationships. Office 365 Outlook Track calendar events. Office 365 Office 365 integration including Word & Excel. Microsoft Azure AD Build, run, and manage applications across multiple clouds, on-premises, and at the edge, with the tools and frameworks of your choice, including Single Sign On. Sailpoint Identity & Access Management SailPoint provides enterprise identity governance solutions with on-premises and cloud-based identity management software for the most complex challenges. Tinvento Tinvento is a software platform that enables senior executives including board members responsible for tax and financial matters to automate manual processes in the... --- Transfer Pricing documentation & client management tool for Tax Advisors & Transfer Pricing Services Providers 10 users Unlimited entities and countries Client management dashboard Transfer pricing benchmarking databases Free country references TP Calendar and notifications Work together with your TP team to create and manage Transfer Pricing documentation for your clients. TPGenie Business is transfer pricing documentation software for tax advisors. It is specially designed to accommodate the needs of transfer pricing services providers such as independent transfer pricing specialists, trusts, consultants and accountants. It is an easy to use web-based transfer pricing documentation and management suite. This genius solution helps you and your team to efficiently create, manage and update compliant transfer pricing documentation for your clients, including Local File, Master File and Country-by-Country Reporting. TPGenie Business: Transfer Pricing documentation software for tax advisors Create & manage fully compliant TP documentation for your clients. Document management and workflow. It is easy to share and delegate documents and tasks with your colleagues or your clients using the incorporated status & messaging system. Audit trail enables you to track any changes made by you and your colleagues, review it and accept it or reject it. Easy integration of your existing corporate style documents and best practices (text) libraries, eliminating the need for copy/paste from older documents that may lead to mistakes. Dynamic text templates: you are not limited to a static format which generates hundreds of pages. You can create your own template up to your needs and even whitelabel the... --- Transfer Pricing Documentation Softwarefor multinationals Unlimited users Unlimited entities and countries Workflow Free country references TP Calendar and notifications Create Transfer Pricing documentation for your whole group. Work either centrally or locally. You are undoubtedly aware that transfer pricing has become one of the most important if not the most critical tax issue for multinational organisations. No matter how transparent the practices of a group are, the increased focus by all governments on transfer pricing increases scrutiny and possible audits. It is therefore crucial for all multinationals to ensure that they have proper transfer pricing documentation such as Master file and Local Files in place. For many, it is a struggle to compile TP documentation because of its complexity. In general, many employees and legal entities across the world are involved in the process, while locally transfer pricing is unfortunately often viewed as a lesser priority. On a practical level, we have seen organisations struggle with the uncontrollable amount of Word-files sent back and forth, excerpts from TP documentation manually being copy-pasted and shared via e-mail. This results in a high risk of non-compliance and not having all documents centrally in place in case of an audit. That is what sparked us to provide a solution to limit the time being spent on documentation preparation, making it easier for you to meet the compliance obligation. It is a user-friendly tool that will guide you through all the steps to finalise the transfer pricing documentation. Our software solution TPGenie Enterprise helps... --- Transfer Pricing Benchmarking Database The Transfer Pricing Benchmarking Database is a module which takes the complicated process of performing an economic analysis off your hands: it provides high quality benchmarking studies in few easy steps. It simplifies transfer pricing analyses, including profit and transaction-based analyses. The Transfer Pricing Benchmarking Database is a module which takes the complicated process of performing an economic analysis off your hands: it provides high quality benchmarking studies in few easy steps. It simplifies transfer pricing analyses, including profit and transaction-based analyses. No need anymore to purchase expensive databases and then spend hours or even days on analysing the raw data. We got you covered here. As a tax advisor, MNE or Local Entity, you can create your benchmarks by making arm's-length analyses for tangible and intangible intra-group transactions, intra-group services and intra-group financing. The tool eliminates the need to purchase data from external data providers and makes searching easier thanks to pre-selected results. All comparable companies or agreements in the database are thoroughly checked by our experts. The results can be integrated directly with your transfer pricing documentation tool TPGenie. You can use our Benchmark AI features to automatically crawl & retrieve detailed company information information. You can achieve a 95% accuracy rate in automatically accepting or rejecting your search results with the use of TPGenie Benchmarking AI! The Transfer Pricing Benchmarking Database consists of four search engines. Each of them can be utilised for a different set of results: Upload an external benchmark from... --- An automatic translation module helps generating Master file, Local files, Intercompany Agreements or any other documents in different languages and can help to improve communication between different countries and departments. Translation module can help you generating Master file, Local files, intercompany agreements or any other documents in different languages. With one click on the button, you can now translate instantly from and to another language. Currently, the following languages are implemented and more to follow: Bulgarian Chinese Czech Danish German Greek English (British) English (American) Spanish Estonian Finnish French Hungarian Indonesian Italian Japanese Lithuanian Latvian Dutch Polish Portuguese (all Portuguese varieties excluding Brazilian Portuguese) Portuguese (Brazilian) Romanian Russian Slovak Slovenian Swedish Turkish The translation module could be integrated into the working environment. It can help multinational to improve communication between different countries or departments as well as mitigate potential risks of misunderstanding or misstatement of facts, deviating from set policies. Back to ModulesContact UsYour guide in the world of Transfer PricingHerengracht 301015 BL, Amsterdam+31 20 422 8885linkedinfacebookyoutubeDrop us a message --- The Country-by-Country Reporting (CbCR) Software Tool creates a BEPS Action 13 CbCR in the XML format according to specifications of the OECD and affiliated countries. Additional Ratio analysis can be done to identify risks that need extra attention or clarification in Table 3Are you in need of a tool for generating beps action 13 country-by-country reporting in the xml format according to the specifications of the OECD? TPGenie is here to help you! TPGenie is a user-friendly tool for generating your BEPS Action 13 Country-by-Country reporting in the XML format according to specifications of the OECD and affiliated countries. It is a proven* solution for converting Excel to CbCR XML schema and comes with many features to gather CbC data across your group entities, sanitize the data and perform risk analysis to reduce the risk on additional audits by tax authorities. You can easily upload your Table 1, Table 2 and Table 3 data into the tool by uploading an Excel file or gather the data from your local entities by an easy survey workflow. The tool has a useful dashboard which provides information on issues and warnings related to the data. The CbCR tool performs sanity checks on the data and with one click of a button it is compiled into the correct XML format according to the specifications of the OECD and your reporting country / countries. The software can be used by: Multinational enterprise groups; Law firms; Tax advisors; Accounting companies. Features Import your Country-by-Country Reporting information... --- This module provides an ability to change financials uploaded in a local amount to transaction amount and vice versa as well as visualise the amounts in a currency of choice for a better comparison of the data. The Currency Conversion Module can be used in combination with the following parts and modules of the application: Local File creation: During initialisation of your transactions you can change financials uploaded in a local amount to transaction amount and vice versa. Amounts extracted from Oracle HFM, SAP or any other ERP system can be converted into local amounts. Local File Survey: let the local user change financials to domestic currency or any other currency of their choice. The user has the freedom to change the currency for all figures for a transaction in one go or the user can decide to change the currency manually line by line. Country-by-Country Reporting Module: automatically convert all CbCR financial data to one functional currency (more info). Data evaluation: automatically visualise the amounts in a currency of choice for a better comparison of the data. Back to ModulesContact UsYour guide in the world of Transfer PricingHerengracht 301015 BL, Amsterdam+31 20 422 8885linkedinfacebookyoutubeDrop us a message --- This module is an intercompany agreement management repository and provides numerous of functionalities for managing your intercompany agreements. Easily show all missing agreements for a specific FY, entity or transaction and map potential available agreements automatically. Do you struggle managing the large amount of intercompany agreements in your company? We developed a system to manage and maintain your intercompany agreements to have all files in one central repository. With this tool there is no need anymore to store your agreements on your network or Sharepoint and have endless searches for the right agreement. Intercompany agreement management Unlike paper-based contract management systems, storing all files in one centralised, digital repository allows for optimum compliance and extensive reporting. The intercompany agreement management software offers a centralised portal with features such as search and filter capabilities and audit trails that provide access to your entire contract history with the click of a mouse. Your business can maintain accurate contract history for auditing and keep a full audit trail. The Intercompany agreement management module provides numerous of useful features: A library containing all your intercompany agreements. contracts are organised within a single repository and all contract related information is stored in metadata. A dashboard is displaying the status of all available agreements. Agreements can be uploaded and validated on a central level - You can allow access to this dashboard only to certain users, for example, the legal department of your company. The users who have access to this module are in charge of... --- The Intercompany Agreement Creation Module provides you with the ability to easily create agreements in a clear and efficient manner as well as boost efficiency by automating (digital) signatures and approvals. Multinationals are obliged to possess Intercompany Agreements (ICAs) for each type of transaction. The ICAs can serve as a supporting document to transfer pricing documentation and the tax position of Taxpayer against Tax authorities globally. TPGenie Intercompany agreements software provides you with the ability to easily create and manage ICAs in a clear and efficient manner. We can finalize over 70 IC agreements and get complete signatures in less than a week! Therefore, we will continue using the TPGenie Agreement Creation Module for such purpose. TPGenie Intercompany agreements software The software tool consists of an easy to use library where you can manage your intercompany agreements and an extensive creation tool where your legal department and lawyers can co-work on the creation of contracts. There is even the possibility for digital signing the contracts to speed up the process and not having the hassle of printing, scanning and re-uploading the files. The Inter-company agreements module consists of the following functionality: Workflow: Creation of agreements and contracts including a wide variety of permissions for validating or rejecting and signing the agreements. A library containing all your Intercompany Agreements. A dashboard displaying the overview of all available agreements. Agreements can be uploaded and validated on a central level: You can allow access to this dashboard to the pre-selected users, for example... --- Are you looking for a reliable transfer pricing documentation solution to ensure your business remains fully compliant with transfer pricing regulations? TPGenie offers a comprehensive SaaS software platform designed to simplify and manage your compliance processes efficiently. We invite you to learn more about how TPGenie can benefit your organisation. Simply provide your details below, and we will share detailed information about our transfer pricing software and its capabilities. Our team is ready to assist you in understanding how TPGenie can be tailored to meet your specific needs, helping you achieve seamless compliance. First name (*) Last name (*) Country (*) ---AfghanistanÅland IslandsAlbaniaAlgeriaAmerican SamoaAndorraAngolaAnguillaAntarcticaAntigua And BarbudaArgentinaArmeniaArubaAustraliaAustriaAzerbaijanBahamasBahrainBangladeshBarbadosBelarusBelgiumBelizeBeninBermudaBhutanBoliviaBonaireBosnia & HerzegovinaBotswanaBouvet IslandBrazilBritish Indian Ocean TerritoryBrunei DarussalamBulgariaBurkina FasoBurundiCabo VerdeCambodiaCameroonCanadaCayman IslandsCentral African RepublicChadChileChinaChristmas IslandCocos (Keeling) IslandsColombiaComorosCook IslandsCosta RicaCôte d'IvoireCroatiaCubaCuracaoCyprusCzech RepublicDenmarkDjiboutiDominicaDominican RepublicEcuadorEgyptEl SalvadorEquatorial GuineaEritreaEstoniaEthiopiaFaroe IslandsFijiFinlandFranceFrench GuianaFrench PolynesiaFrench Southern TerritoriesGabonGambiaGeorgiaGermanyGhanaGibraltarGreeceGreenlandGrenadaGuadeloupeGuamGuatemalaGuernseyGuineaGuinea-bissauGuyanaHaitiHeard Island And McDonald IslandsHondurasHong KongHungaryIcelandIndiaIndonesiaIranIraqIrelandIsle Of ManIsraelItalyJamaicaJapanJerseyJordanKazakhstanKenyaKiribatiKoreaKuwaitKyrgyzstanLao People's Democratic RepublicLatviaLebanonLesothoLiberiaLibyaLiechtensteinLithuaniaLuxembourgMacaoMacedoniaMadagascarMalawiMalaysiaMaldivesMaliMaltaMarshall IslandsMartiniqueMauritaniaMauritiusMayotteMexicoMicronesiaMoldovaMonacoMongoliaMontenegroMontserratMoroccoMozambiqueMyanmarNamibiaNauruNepalNetherlandsNew CaledoniaNew ZealandNicaraguaNigerNigeriaNiueNorfolk IslandNorthern Mariana IslandsNorwayOmanPakistanPalauPalestinian TerritoryPanamaPapua New GuineaParaguayPeruPhilippinesPitcairnPolandPortugalPuerto RicoQatarReunionRomaniaRussian FederationRwandaSaint BarthélemySaint Kitts And NevisSaint LuciaSaint Pierre And MiquelonSaint Vincent And The GrenadinesSamoaSan MarinoSao Tome and PrincipeSaudi ArabiaSenegalSerbiaSeychellesSierra LeoneSingaporeSlovakiaSloveniaSolomon IslandsSomaliaSouth AfricaSouth Georgia And The South Sandwich IslandsSouth SudanSpainSri LankaSudanSurinameSvalbard And Jan MayenSwedenSwitzerlandSyrian Arab RepublicTaiwanTajikistanTanzania, United Republic OfThailandTimor-LesteTogoTokelauTongaTrinidad And TobagoTunisiaTurkeyTurkmenistanTurks And Caicos IslandsTuvaluUgandaUkraineUnited Arab EmiratesUnited KingdomUnited StatesUnited States Minor Outlying IslandsUruguayUzbekistanVanuatuVenezuelaViet NamVirgin Islands (British)Virgin Islands (US)Wallis And FutunaWestern SaharaYemenZambiaZimbabwe Business E-mail (*) Company (*) Website I am (*) ---representing a Multinational Enterpriserepresenting a Local Entitya Tax Advisor serving 0-5 clientsa Tax Advisor serving more than 5 clientsOther I am interested in (*) TPGenie BusinessTPGenie BasicTPGenie EnterpriseBenchmarking ModuleCreating and... --- Transfer Pricing Documentation Softwarefor local entities or tax advisory companies 1 user 1 environment Free MF & LF templates Easy 4 step creation of Local file Create & Manage Transfer Pricing documentation. Be compliant in a few clicks! TPGenie Basic is an easy to use web-based transfer pricing documentation solution for local entities or small advisory companies. This genius solution helps you to efficiently create and update compliant transfer pricing documentation, including Local File, Master File and all necessary appendixes. Transfer pricing documentation software for local entities or small advisory companies Creation of Local File in just 4 easy steps - fully OECD and Country specific compliant transfer pricing documentation. Free Master file templates, Local file templates and country references included (read more info on the local file template in our blog! ) ChatGPT's artificial intelligence included for free, to assist you in writing Functional analysis' functions, risks, and assets and retrieve summarised country-related data. Read more info on our integration of ChatGPT in transfer pricing software TPGenie. Free transfer pricing benchmarking databases included, to establish at arm’s length remuneration on tangible and intangible intra-group transactions, services and financing. Transfer Pricing Guide and Transfer Pricing Calendar included. Intuitive and easy to use - no extensive knowledge of transfer pricing required. Extensive help functionality and outstanding support from our experienced TP experts. Easy integration of your existing TP documentation and economic analysis. Pixel perfect document formatting. Benchmarking databases included TPGenie Basic takes the complicated process of performing an economic analysis off... --- Who we are Intra Pricing Solutions is an independent and specialist provider of transfer pricing related software solutions, with the headquarters in Amsterdam. Our company was established in 2009 and for more than a decade has been a leading provider of transfer pricing software to multinationals and advisory companies. Through the years, our clients played an essential role in the continuous development of TPGenie. This transfer pricing software solution and additional enhancement modules have been trusted by hundreds of multinational companies and their advisors worldwide. With every update and release of additional features, we are implementing the wishes of the users, creating the efficiency, focus and transparency our customers need to get their best work done.  Contact UsYour guide in the world of Transfer PricingHerengracht 301015 BL, Amsterdam+31 20 422 8885linkedinfacebookyoutubeDrop us a message --- For more than a decade TPGenie Transfer Pricing documentation software is the one-stop solution for creating & managing Transfer Pricing documentation, including Local Files, Master Files, Benchmarks, Inter-Company Agreements, Country-by-Country Reporting and much more. Hundreds of Multinationals, Tax Advisors and Local Entities are using the AI-powered TPGenie Transfer Pricing Documentation Software to increase compliance and reduce costs. Join over 350 customers using TPGenieTPGenie Basic Transfer Pricing documentation software for Local entities or Tax advisory companies 1 user 1 environment Free Master file & Local file templates Easy 4 step creation of Local file Transfer pricing benchmarking databases Free ChatGPT AI integration Create & Manage Transfer Pricing documentation. Be compliant in a few clicks! TPGenie Business Transfer Pricing documentation & client management tool for Transfer Pricing Services Providers 10 users Unlimited entities and countries Client management dashboard Transfer pricing benchmarking databases Transfer Pricing guide & country deadlines Client calendar and notifications Compliance tracker Work together with your TP team to create and manage Transfer Pricing documentation for your clients. TPGenie Enterprise Transfer Pricing documentation, workflow & dashboard tooling for Multinationals Unlimited users Unlimited entities and countries Workflow: Review, Validate & Approve Local files. Automatic translation of Local files TP Calendar & notifications IC-Agreement Database Create Transfer Pricing documentation for all entities in your MNE group, either centralised or decentralised. TPGenie simplifies the creation, updating, and management of transfer pricing documentation, including Master files, Local files, Intercompany Agreements, Benchmarking databases, Pillar Two, and Country-by-Country Reporting. It supports transfer pricing planning, risk management,... --- TPGenie ProductsTPGenie Basic Transfer Pricing documentation software for Local entities or Tax advisory companies 3 users 1 environment Free Master file & Local file templates Easy 4 step creation of Local file Transfer pricing benchmarking database Free ChatGPT AI integration Create & Manage Transfer Pricing documentation. Be compliant in a few clicks! TPGenie Business Transfer Pricing documentation & client management tool for Transfer Pricing Services Providers 10 users Unlimited entities and countries Client management dashboard Free country references Transfer Pricing guide & country deadlines Client calendar and notifications Compliance tracker Work together with your TP team to create and manage Transfer Pricing documentation for your clients. TPGenie Enterprise Transfer Pricing documentation, workflow & dashboard tooling for Multinationals Unlimited users Unlimited entities and countries Workflow: Review, Validate & Approve Local files. Automatic translation of Local files TP Calendar & notifications IC-Agreement Database Create Transfer Pricing documentation for all entities in your MNE group, either centralised or decentralised. TPGenie ModulesBenchmarking Database The Benchmarking Database takes the complicated process of performing an economic analysis off your hands: it provides high quality benchmarking studies in few easy steps. It simplifies transfer pricing analyses, including profit and transaction-based analyses. Benchmarking Database The Benchmarking Database takes the complicated process of performing an economic analysis off your hands: it provides high quality benchmarking studies in few easy steps. It simplifies transfer pricing analyses, including profit and transaction-based analyses. Pillar Two Navigate the complexities of global minimum tax with our innovative tool. Designed for multinational enterprises and tax... --- --- ## Posts One of the most common risks in transfer pricing documentation is inconsistency between the Local File and the Country-by-Country Report (CbCR). While both serve different purposes, tax authorities increasingly compare these reports side by side to identify red flags. Even small mismatches in revenues, profits, FTE headcounts, or business unit descriptions can lead to questions, audits, and potential penalties. With TP Copilot, our AI-powered compliance tool inside TPGenie, this risk is minimized. The cross-checking feature automatically validates whether the information reported in your Local File matches the data in the CbCR. It identifies inconsistencies in key financial figures, employee numbers (FTE), transaction descriptions, and entity-level business information—before the reports are submitted. For multinational enterprises, this means confidence that their files tell one consistent story across jurisdictions. For consultants, it accelerates review work and reduces the chance of oversight. And for compliance teams, it ensures that audit readiness becomes part of the process, not an afterthought. By bridging the Local File and CbCR, TP Copilot helps you avoid fines, reduce audit exposure, and deliver documentation that withstands regulatory scrutiny. Learn more and see TP Copilot in action in our video: Schedule a demo --- In transfer pricing, details matter. A small mismatch between a TP Form and a Local File can trigger extensive audits, fines, and countless hours of extra work. With documentation spread across multiple files, entities, and years, even the most experienced tax teams and consultants face the challenge of keeping everything perfectly aligned. That’s where TP Copilot, our AI-powered compliance partner inside TPGenie, changes the game. TP Copilot is more than a validation tool. It acts as an intelligent reviewer, detecting mismatches, inconsistencies, and missing information before documents are submitted. By cross-checking Local Files, Master Files, Country-by-Country reports, appendices, and agreements, TP Copilot ensures your transfer pricing documentation is always consistent, audit-ready, and penalty-free. For multinational enterprises, this means peace of mind: reports can be validated proactively, year-on-year reconciliations are automated, and compliance with local requirements becomes seamless. For tax consultants, TP Copilot accelerates review work, helps train junior staff by highlighting common errors, and frees up time for higher-value client work. And for tax authorities, it offers a fast, reliable way to run red-flag checks, benchmark documentation, and prioritize audits with greater efficiency. The result is confidence. With TP Copilot, transfer pricing compliance moves from being a stressful, manual process to a streamlined, AI-backed safeguard. It reduces workload, improves accuracy, and helps you stay fully prepared for any audit. Watch our video to see TP Copilot in action and learn how it can help you prevent audits and fines: Schedule a demo --- At TPGenie, we continuously enhance our platform to give multinational enterprises (MNEs) and tax professionals the tools they need to stay on top of ever-evolving global transfer pricing and tax compliance requirements. As part of our latest update, we have significantly expanded the Compliance Tracker with a wide set of new fields. These additions are designed to give users a complete 360-degree overview of compliance obligations, from Master File preparation to Pillar Two implementation. Starting with FY 2025, these fields will be active and populated with the latest country-specific requirements. What’s New in the Compliance Tracker? We have added numerous new fields to the Compliance Tracker, resulting in the below total set of fields. Master File MF Completed – Confirm preparation of the Master File. MF Deadline & MF Deadline Description – Track filing timelines with contextual detail. Local File LF Completed – Track preparation of Local Files. LF Required to submit / LF Filed – Distinguish between requirement and actual submission. LF Deadline & LF Deadline Description – Monitor country-specific deadlines. Language Required – Capture language requirements for local compliance. Country-by-Country Reporting (CbCR) CbCR Notification Filed – Confirm notification compliance. CbCR Notification Deadline & Deadline Description – Stay ahead of notification cut-offs. CbCR Notification Portal URL – Direct links to filing portals. CbCR Filing Deadline & Description – Track formal CbCR submissions. CbCR Exchange Countries – Identify automatic exchange jurisdictions. CbCR Local Filing – Flag where local filing applies. CbCR Filing Portal URL – Simplify access to country filing... --- Why TP Forms matter in Transfer Pricing compliance In global Transfer Pricing compliance, attention often goes to preparing strong local files and master files. Yet, the Transfer Pricing forms (TP Forms) filed with local tax authorities are just as important. These forms summarise key data from the local file, but too often they are treated as a last-minute exercise. When TP Forms are incomplete, inconsistent, or misclassified, the risks are high: penalties, audits, and reputational damage. For multinational enterprises, avoiding these issues is critical. What goes wrong today in TP Form compliance Wrong data and misclassifications Local teams without Transfer Pricing expertise often submit incorrect financials or confuse methods (e. g. , cost plus vs. TNMM). These errors quickly undermine compliance and may trigger penalties. Discrepancies between local file and TP form A frequent issue is that the TP Form data does not match the local file. Without a structured cross-check, inconsistencies slip through, raising red flags with authorities. Inconsistent terminology across jurisdictions Countries describe transactions differently: “procurement,” “purchase of goods,” or “sale of goods. ” Without a translation layer, these differences create mismatches between TP Forms and documentation. Human errors from manual workflows Copy-pasting between Excel, XML, PDF, or web forms introduces mistakes. We have heared about cases where the local teams even used wrong entity names (e. g. , “MNE Group Supply Chain” vs. “MNE Group Supply Inc. ”) creating unnecessary inconsistencies between TP Form and local file documentation. Complex and changing form requirements Some jurisdictions require totals... --- Even the most experienced transfer pricing professionals face challenges in ensuring flawless documentation. Hidden pitfalls like inconsistent profit margins, outdated comparables, or narrative-data mismatches can easily slip through human review. This is where artificial intelligence (AI) is making a meaningful impact, not by replacing expert judgment, but by augmenting it. AI-powered tools are now helping multinational companies detect, diagnose, and flag errors that might otherwise go unnoticed, strengthening the integrity and defensibility of transfer pricing documentation. Here are six practical ways AI supports transfer pricing teams in avoiding costly mistakes, illustrated with real-world examples: 1. Detecting Inconsistent Profit Margins Across Countries The Challenge: A company’s subsidiaries performing similar functions sometimes report significantly different profit margins. Such inconsistencies can raise audit flags and suspicions of profit shifting. How AI Helps: AI tools analyse profit margins across jurisdictions, identifying significant deviations and prompting professionals to investigate and justify differences. Real-Life Example: A global technology firm once faced intense scrutiny from tax authorities after disparate margins were reported across its European subsidiaries. Using AI analytics, they uncovered misallocated expenses causing margin distortion and quickly corrected their filing that significantly reduced audit risks. 2. Spotting Outdated or Incomplete Benchmark Sets The Challenge: Benchmark studies often rely on comparable companies, but databases evolve as companies go private, are delisted, or change operations. Using outdated benchmarks undermines report credibility. How AI Helps: AI can validate benchmark sets by flagging inactive comparables or missing data years, and suggest newer, more relevant peers based on real-time data. Real-Life... --- Transfer pricing documentation has come a long way from clunky Word templates and last-minute data chasing. As global regulations tighten and tax authorities demand more nuanced, defensible reporting, the expectations for local files have evolved. It’s no longer just about compliance, it’s about consistency, accuracy, and speed. The future of transfer pricing documentation lies in intelligent automation. Modern tax teams need tools that do more than automate repetitive tasks, they need solutions that elevate the entire documentation process, turning it from a manual burden into a strategic advantage. What Does Intelligent Local File Automation Look Like? Many transfer pricing software solutions offer basic template automation that includes standardised text blocks, dropdown selections, and some pre-filled data. However, true innovation integrates artificial intelligence across the entire local file lifecycle. This approach allows the software to: Generate tailored narrative content for critical sections like functional analyses, transaction descriptions, and economic characterizations. Analyse transactional data to identify anomalies or inconsistencies before reports are finalised. Cross-reference previous filings to maintain internal consistency and reduce compliance risk. Provide contextual guidance in real-time, flagging missing information and suggesting sample wording to improve report quality. Rather than merely speeding up form completion, intelligent automation delivers smarter, cleaner, and more audit-ready documentation that’s quickly and reliably. How AI is Transforming the Local File Process Narrative Drafting with Minimal Manual Effort - Preparing local files often involves hours of writing to explain business activities and inter-company transactions. AI-powered tools can draft these narratives by leveraging prior-year filings, current financial... --- The transfer pricing landscape is undergoing a rapid transformation. As data volumes grow and regulatory demands intensify, TP professionals are expected to do more than ensure compliance and deliver strategic value to the business. Artificial Intelligence (AI) is now at the centre of this shift. To remain competitive and future-ready, TP professionals must develop new capabilities. They must become AI-literate, strategic thinkers who can partner with the business and leverage advanced tools effectively. The good news: The next generation of professionals doesn’t need to become data scientists. They need to become AI-enabled advisors. Here's what that means, and how learning from AI-leading companies can accelerate the journey. The Skills Transfer Pricing Professionals Need in an AI Era An AI-era TP professional blends tax expertise with data intuition and tech fluency. They don’t build algorithms, but they know how to use AI to their advantage. Key capabilities include: AI Literacy: Understanding the role of AI in TP workflows and how to interpret AI-generated insights within legal and regulatory frameworks (e. g. , OECD Guidelines, local tax laws). Digital Agility: Comfort with cloud-based platforms, dashboards, and data visualizations that help track risks and performance in real-time. Analytical Thinking: The ability to evaluate anomalies, assess risk signals, and apply judgment to AI-flagged issues. Strategic Communication: Translating complex findings into actionable business insights and advising leadership on cross-border pricing decisions. Collaboration Skills: Working across tax, finance, and IT to ensure policies are not just compliant—but digitally integrated and future-proof. AI-native TP professionals distinguish themselves... --- In the evolving world of transfer pricing, the burden of documentation has grown heavier, more jurisdictions, more complexity, tighter deadlines. But leading-edge tax functions are turning this challenge into an opportunity, using Artificial Intelligence (AI) to transform how documentation is created, reviewed, and validated. At the forefront of this shift is TPGenie from Intra Pricing Solutions, a platform that goes beyond automation and into intelligent enablement. Let’s pull back the curtain to show how AI is working behind the scenes in TPGenie, reshaping how modern tax teams approach transfer pricing documentation—and what that means for the future of the function. AI-Powered Documentation: A Shift from Manual to Meaningful Traditionally, transfer pricing documentation has been labour-intensive, by gathering data, formatting narratives, running benchmarking analyses, converting currencies, and checking local compliance boxes. TPGenie is changing this by embedding AI across its core modules, making documentation faster, smarter, and more strategic. One of the most visible applications of AI is TPGenie’s AI Writing Assistant, integrated via ChatGPT. This feature helps tax professionals draft and refine sections of the local file, including functional and economic analyses, with greater consistency and quality. The assistant reviews grammar, detects structural inconsistencies, and highlights possible logic gaps, helping ensure that narrative quality matches the technical accuracy expected by tax authorities. Rather than replacing human expertise, this AI module augments it by freeing professionals to focus on higher-value work like interpreting policy, advising the business, and preparing for audits. AI in Benchmarking: From Raw Data to Defensible Insights Benchmarking... --- In 2025, transfer pricing compliance continues to be a core challenge for multinational enterprises (MNEs), particularly within the EU where BEPS Action 13, Local File/Master File obligations, and Pillar Two initiatives require sophisticated documentation processes. The rise of AI, cloud integration, and global regulatory updates have led to the emergence of several transfer pricing software solutions aimed at reducing risk, increasing automation, and improving audit readiness. Below is a curated list of the top 10 transfer pricing documentation tools for 2025, focusing on software used by MNEs. These platforms are compared based on functionality, ERP integration, security readiness, pricing, and client base. 1. TPGenie TPGenie is a full-suite SaaS solution designed for complex MNEs needing automated Local/Master Files, intercompany agreements, CbCR & Pillar Two support, and multilingual documentation. It includes an AI validation module named TP Copilot and powerful workflow controls. With a high functionality score and full security compliance, TPGenie is built to scale. 2. Aibidia Aibidia integrates AI, ERP data feeds, benchmarking, and IBFD-backed tax research. Aibidia's TP Aurora module enables rapid document creation, P&L segmentation, and CbCR automation. It excels in integration and workflow visualization, ideal for MNEs embracing digital transformation. 3. Reptune Reptune (formerly TP Tuned) provides automated Local and Master File generation, CbCR output, and AI-assisted translation and industry research. With fast implementation and strong support, it's well-suited for MNEs aiming to reduce documentation effort by 50% or more. 4. PwC globalDoc Solution® PwC's globalDoc is a high-end solution tailored to large MNEs requiring jurisdiction-specific... --- AI is opening up new possibilities for transfer pricing. It’s not just about keeping up with compliance anymore, it’s about moving faster, working smarter, and getting more value from your data. Tax teams around the world are starting to embrace AI to make their lives easier and their documentation stronger. From automating local files to spotting risks early and supporting big-picture planning, AI is helping companies do more with less. We’re seeing a shift in mindset. Transfer pricing is no longer just a box to tick for tax authorities. With the right tools, it becomes a real driver of insights and strategic value. How AI Helps Across the TP Lifecycle Let’s break it down a bit further. Here’s how AI is already improving key areas of transfer pricing: Documentation Made Simple AI tools can generate master and local files by pulling from different systems including finance, legal, operations, and then piecing it all together in a clear, consistent format. Some tools summarize intercompany agreements using natural language processing (NLP), saving hours of manual work. Better Audit Readiness Audits are getting more data driven. AI can simulate common audit questions based on past cases or specific country rules, helping you get ahead of potential challenges. One recent example was where our TP Copilot AI software solution was used to spot inconsistencies between functional analyses and financial outcomes before submitting files and cutting down audit exposure significantly. Live Risk Monitoring With AI constantly scanning transactional and financial data, it’s easier to spot... --- TPGenie continues to lead the way in streamlining global transfer pricing compliance — and we’re excited to announce our latest enhancement: the full implementation of the German Transfer Pricing Transaction Matrix. Designed to meet the latest requirements set by the German tax authorities, the German Transaction Matrix is now available in TPGenie and fully aligned with Example 1 of the official specification issued by the German Ministry of Finance. You can review the official BMF documentation here: BMF Schreiben – Transaktionsmatrix vom 2. April 2025 (PDF) What is the German Transfer Pricing Transaction Matrix? The German Transaction Matrix is a structured table that outlines key intercompany transactions and must be included in the local file as per §90 AO requirements. It supports German tax authorities in performing risk assessments and is increasingly expected in audits and documentation reviews. TPGenie now automatically generates this matrix for each relevant entity, including all required fields such as: Transaktionstype Beteiligte Parteien Funktions- und Risikoanalyse Verrechnungspreismethode Vertragliche Grundlage Volumen Abweichung von der Regelbesteuerung If the fields “Volumen”, “Vertragliche Grundlage”, and “Abweichung von der Regelbesteuerung” may be blank if this data was not tracked in previous years. If you’d like to start populating these fields going forward, we can activate them in your Financial Details upload configuration. This ensures seamless integration into future (and even retrospective) documentation cycles. How to Include the Matrix in Your Local File Adding the German Transaction Matrix to your transfer pricing documentation is easy in TPGenie. Simply insert the following variable... --- AI is no longer a “nice to have” in transfer pricing, it’s already here, reshaping how tax teams handle documentation, benchmarking, and risk monitoring. Many multinational enterprises (MNEs) are well on their way to integrating AI into their TP processes, using it to speed up compliance, reduce human error, and surface risks in real time. But there’s still one key question for tax and finance leaders: Can AI really understand and apply the arm’s length principle (ALP)? Short answer: not completely. But it can do a lot of the heavy lifting, and when used wisely, it becomes an incredibly powerful tool for getting TP right faster, more consistently, and with better insight. AI Is Already Supporting ALP Compliance and Here’s How: Let’s be clear: AI isn’t just a buzzword anymore. It's actively transforming how companies manage some of the most complex and time-consuming parts of transfer pricing. Take benchmarking. Historically, screening for comparable companies meant hours—sometimes weeks—of manual database work. Now, machine learning can instantly score potential comparables based on financial metrics, SIC codes, and even qualitative text in company descriptions. For instance, some companies are using AI models to rank 2,000+ companies by relevance, filter them by functional profile, and produce a clean, documented selection set, all in a few clicks with TPGenie's Benchmarking AI. With Natural Language Processing (NLP), AI can now auto-generate portions of local file reports. Companies are feeding AI tools with ERP data and having first drafts of Chapter 3 (financials) ready within minutes. This... --- As global tax regulations grow more complex, the world of transfer pricing is undergoing a major transformation—powered by artificial intelligence. From real-time compliance to machine-readable filings, transfer pricing AI is not only changing how we document, but what documentation even looks like. In this blog, we’ll explore the future of transfer pricing compliance—fueled by AI and structured data—and break it down into short-term, mid-term, and long-term trends that every multinational and tax professional should prepare for. We can help you transitioning to a Transfer Pricing AI fueled eco system using our Transfer Pricing Copilot software solution. Short-Term (Today to 2 Years): Transfer Pricing AI as a Smart Assistant We’re already in the first phase of the transfer pricing AI revolution. Today’s AI tools help tax professionals: Review transfer pricing documentation for missing sections or inconsistent narratives Check compliance with OECD guidelines and local regulations Generate draft TP reports using structured data and pre-set logic Flag red flags before submission with real-time risk indicators But there’s a parallel transformation happening: the format of TP documentation itself is evolving. Tax authorities are introducing structured TP forms—such as the recently updated Belgium 275. LF Form, India’s Form 3CEB, and Poland’s TPR-C—moving away from long, narrative-heavy local files. These forms are machine-readable, making them ideal for AI-driven transfer pricing analysis and future automation. Medium-Term (3 to 5 Years): Standardized Data, Predictive Audits, and Government AI In the near future, transfer pricing AI won’t just assist—it will audit, analyze, and even anticipate. Governments will begin... --- Imagine creating transfer pricing documents that practically write themselves. That's exactly what our April 2025 update at TPGenie delivers. The Template Revolution is Here Remember the old days of endless copying and pasting between entity files? The tedious hours spent updating multiple documents when tax rules change? Those days are officially over. Our new smart template system lets you create documents that automatically adapt to each country and entity. Write once, use everywhere – it's that simple. How It Works (Without the Tech Talk) Think of it as having a brilliant assistant who knows exactly which content belongs where. You create a section about French tax requirements once, and it magically appears in every French entity's documentation – perfectly formatted and always up-to-date. When regulations change, you update in one place and every document reflects those changes instantly. No hunting through files, no risk of missing updates. What This Means For You Documents that practically build themselves Consistency across all your TP files Hours (maybe days) saved on documentation Freedom to focus on strategy, not paperwork Whether you're handling TP for multiple clients or managing your company's global compliance, this is the game-changer you've been waiting for. Want to see how it works in action? Book a demo or reach out to our team—we’d love to show you. Smart templates. Less busywork. More impact. Book a DEMO --- Last week, we had the pleasure of hosting the TPGenie Users Day 2025, bringing together transfer pricing professionals from across the globe for a day of learning, sharing, and collaboration. The event, generously hosted at H&M's premises by Rika Yamane and Erik Knijnenburg, provided a unique opportunity for our users to connect face-to-face and share their experiences with TPGenie. A Day of Insights and Exchange The day was filled with engaging discussions on the challenges that transfer pricing teams face in today's complex regulatory environment. From documentation requirements and Pillar Two implementation to resource constraints and tight deadlines, our users openly shared their pain points and success stories. What made the event truly special was the candid feedback and constructive suggestions we received. Our users didn't hold back – they told us exactly what works well in TPGenie and where they see opportunities for improvement. This kind of honest dialogue is invaluable for us as we continue to develop our platform. Key Themes and Priorities Several clear priorities emerged from our discussions: 1. Pillar Two Reporting The implementation of Pillar Two has created new compliance challenges for multinational enterprises. Our users expressed a strong need for enhanced automation in this area, with particular interest in capabilities that would streamline reporting processes and ensure accuracy. 2. Improving ICA Validation Intercompany Agreement (ICA) management remains a significant challenge. Users highlighted the need for more sophisticated validation processes to prevent duplication and ensure completeness, with specific requests for metadata validation and automated cross-checks.... --- In today’s interconnected world, data and technology are revolutionizing the way multinational enterprises (MNEs) approach transfer pricing. The increasing complexity of global regulations, coupled with the need for transparency and efficiency, has made leveraging advanced tools and robust data management strategies more critical than ever. For MNEs, the integration of technology into transfer pricing processes is no longer a choice but a necessity. This blog explores the pivotal role of data and technology in transfer pricing, the challenges they address, and the strategies MNEs can adopt to stay ahead. The Future of Transfer Pricing: How Data and Technology Are Transforming Compliance and Strategy As global tax regulations tighten and tax authorities demand greater transparency, multinational enterprises (MNEs) face increasing pressure to ensure their transfer pricing policies align with the arm’s length principle. Data and technology are revolutionizing the way MNEs manage transfer pricing, enhancing compliance, improving efficiency, and providing strategic insights that drive business success. The Role of Data and Technology in Transfer Pricing Automating Compliance Processes By leveraging automation, MNEs can streamline documentation, benchmarking, and reporting, significantly reducing the time and effort required for compliance. Enhancing Accuracy Data-driven solutions ensure consistency across jurisdictions, minimizing errors and discrepancies in intercompany pricing. Strengthening Audit Readiness Advanced tools enable quick retrieval and analysis of data, making audits more manageable and reducing regulatory risks. Driving Strategic Insights With the power of advanced analytics, MNEs can optimize transfer pricing strategies and align them with broader business objectives, improving profitability and tax efficiency. Key Challenges... --- Transfer pricing continues to be a top priority for tax authorities worldwide, with regulations evolving and audit scrutiny intensifying. For multinational enterprises (MNEs), compliance is no longer just about ticking the right boxes, it requires a proactive, strategic approach to minimize risks and ensure operational efficiency. Key Regulatory Changes Impacting Transfer Pricing Recent global tax reforms—such as the OECD’s BEPS framework, the global minimum tax under Pillar Two, and jurisdiction-specific regulations—are making compliance more complex than ever. These shifts are forcing MNEs to rethink their transfer pricing strategies, enhance documentation, and strengthen internal controls. OECD’s Pillar Two and the Global Minimum Tax The introduction of a 15% global minimum tax under Pillar Two is a game-changer for transfer pricing. This framework ensures MNEs pay a minimum level of tax regardless of where they operate, directly impacting intercompany pricing—especially for entities in low-tax jurisdictions. As a result, companies must reassess their transfer pricing structures to align with the new global tax landscape. Increased Localization of Regulations Countries are tightening their transfer pricing rules, introducing stricter documentation requirements, enhanced transparency measures (such as Country-by-Country Reporting (CbCR)), and harsher penalties for non-compliance. The result? MNEs must now navigate a fragmented regulatory environment while ensuring global consistency. Digitalization of Tax Administration Tax authorities are rapidly adopting advanced data analytics and AI-driven tools to detect anomalies in intercompany transactions. Digital audits are becoming more precise, making real-time compliance crucial for MNEs. Accurate and timely reporting is no longer optional—it’s essential. Substance Over Form: A Growing... --- Transfer pricing disputes have become a critical area of focus for multinational enterprises (MNEs) as tax authorities worldwide ramp up their scrutiny of intercompany transactions. These disputes, often arising from differing interpretations of the arm’s length principle, pose significant risks to MNEs, including financial penalties, double taxation, and reputational damage. Recent disputes In recent years, several high-profile cases have underscored the complexities and challenges inherent in transfer pricing: Coca-Cola's $6 Billion Tax Dispute In a protracted legal battle spanning nearly two decades, Coca-Cola faced a significant transfer pricing dispute with the U. S. Internal Revenue Service (IRS). The contention centered on the company's allocation of profits from foreign licensing arrangements. In 2024, the U. S. Tax Court ruled against Coca-Cola, resulting in a $6 billion liability in back taxes and interest. The company has announced plans to appeal the decision. Apple's €13 Billion Tax Case with the European Union Apple became embroiled in a landmark transfer pricing dispute when the European Commission ordered the company to pay €13 billion in back taxes, alleging that it had received unlawful state aid from Ireland through favorable tax arrangements. In 2024, the European Court of Justice ruled against Apple, upholding the Commission's decision. This case has significant implications for how multinationals manage their profits and tax strategies within the EU. Common Areas of Transfer Pricing Disputes These cases highlight the growing landscape of transfer pricing disputes, driven by factors such as inconsistent interpretation of rules across jurisdictions, heightened focus on base erosion and... --- P&L Segmentation Tool The P&L Segmentation Tool enables organisations to build, manage, and populate segmented Profit & Loss statements within TPGenie. This module helps structure financial data across multiple dimensions like product lines, business units, and regions, while ensuring alignment with transfer pricing documentation requirements. Template Management At the heart of the P&L Segmentation Tool lies its powerful template management system. Users can design custom P&L templates that perfectly match their organisational needs, incorporating flexible line items and diverse segmentation options. The system includes automated calculation formulas for key financial metrics, ensuring accuracy and consistency. When a new financial year begins, templates can be efficiently transferred while maintaining their structural integrity. Multi-dimensional Segmentation The tool excels in handling complex organisational structures through its multi-dimensional segmentation capabilities. Supporting up to three concurrent segmentation dimensions, users can analyse their financial data through various lenses - whether by business units, product lines, regions, or any custom categories that matter to their organisation. All this information is presented in a unified interface that displays both consolidated and segmented views. Data Integration & Population Data handling is both flexible and precise. Users can input data manually with built-in validation checks or leverage the automated data structuring capabilities of TP Copilot. The system supports direct imports from Excel and other financial systems, with intelligent mapping features that ensure data aligns correctly with template structures. This dual approach to data entry accommodates various organisational workflows and data sources. Compliance & Reporting The tool seamlessly integrates with Local... --- Understanding P&L Segmentation for Transfer Pricing Compliance P&L segmentation represents a critical component of transfer pricing documentation for multinational enterprises (MNEs). This comprehensive guide explores how proper profit and loss segmentation supports transfer pricing compliance, enhances transparency, and helps organizations navigate complex international tax requirements. What is P&L Segmentation in Transfer Pricing? P&L segmentation in transfer pricing refers to the systematic breakdown of financial performance across different business units, geographical locations, and product lines within a multinational organization. This segmentation process specifically focuses on isolating and analyzing profits and losses related to controlled transactions between related entities. Key benefits of P&L segmentation in transfer pricing include: Value Chain Alignment: Demonstrates how profits correlate with value creation across different entities within the corporate group. Risk Assessment: Provides clear visibility into how different business segments contribute to overall profitability while managing transfer pricing risks. Compliance Documentation: Supports detailed financial reporting requirements for transfer pricing documentation, including local files and country-by-country reporting. P&L Segmentation Methodology for Transfer Pricing 1. Establishing Segmentation Criteria When implementing P&L segmentation for transfer pricing purposes, organizations should consider multiple segmentation approaches: Function-based segmentation (manufacturing, distribution, R&D) Geographic segmentation (by tax jurisdiction) Product-based segmentation (by product line or service category) Transaction-based segmentation (by type of controlled transaction) 2. Data Collection and Validation Accurate P&L segmentation requires comprehensive financial data collection: Transactional data from enterprise resource planning (ERP) systems Cost accounting records Revenue recognition details Intercompany transaction documentation Supporting documentation for cost allocations 3. Cost Allocation Methodologies For accurate P&L... --- In today’s interconnected global economy, cross-border intercompany financing has become a cornerstone of multinational enterprises (MNEs) seeking to optimize their financial structures. However, managing these transactions effectively requires navigating a maze of tax regulations, compliance requirements, and economic challenges. To ensure success, MNEs must adopt a strategic approach that balances operational needs with regulatory obligations while minimizing risks. The Landscape of Cross-Border Intercompany Financing The rise in cross-border intercompany financing transactions—such as loans, advances, and guarantees—between related entities in different jurisdictions has become a key aspect of multinational operations. These arrangements play a crucial role in optimizing working capital, funding strategic investments, and enhancing tax efficiency. However, they are increasingly subject to rigorous scrutiny by tax authorities, given their potential implications for profit shifting and erosion of the tax base. Recent global developments, including the OECD’s Base Erosion and Profit Shifting (BEPS) initiative and the implementation of Pillar Two’s global minimum tax, have heightened regulatory oversight of intercompany financing arrangements. Notably, new German transfer pricing rules introduced under the Foreign Tax Act (FTA) for 2024 impose stricter provisions, including a three-prong test for debt capacity, business purpose, and maximum interest rates. These changes emphasize the need for MNEs to align financing terms closely with the arm’s length principle. Challenges in Cross-Border Intercompany Financing MNEs encounter several challenges when structuring and managing intercompany financing transactions: 1. Regulatory Compliance Tax authorities worldwide require intercompany transactions to comply with the arm’s length standard, which dictates that terms and conditions must align with those... --- As the global trade keeps evolving, tax authorities around the world have become more vigilant in scrutinizing transfer pricing practices. The potential for profit shifting, where MNEs may move profits to lower-tax jurisdictions to reduce their overall tax liability, has led to a significant rise in transfer pricing audits and disputes. These disputes can have serious financial consequences, from large tax reassessments and penalties to prolonged legal battles. To mitigate these risks, MNEs need robust documentation practices that can demonstrate their compliance with the arm’s length principle—the standard used to evaluate whether intercompany transactions are priced similarly to transactions between unrelated entities. Below we will explore the evolving landscape of global transfer pricing disputes and highlights how specialized transfer pricing documentation software can play a crucial role in mitigating risks. Contributing factors to Transfer Pricing Disputes Increased Scrutiny by tax authorities worldwide have enhanced their transfer pricing regulations and enforcement mechanisms, deploying better tools and methodologies to detect potential profit shifting. MNEs engage in a wide range of transactions between related entities, including the sale of goods, provision of services, licensing of intellectual property, and financing arrangements. The complexity and diversity of these transactions make it difficult to ensure consistent pricing that adheres to the arm’s length principle across different jurisdictions. Tax authorities require MNEs to maintain comprehensive and detailed documentation that justifies their transfer pricing policies. This documentation should demonstrate that intercompany transactions are priced in accordance with the arm’s length principle, providing supporting economic analyses, comparable data, and... --- In today’s global economy, intangible assets—such as intellectual property (IP), brand value, and proprietary technologies—have become pivotal drivers of value and competitive advantage for multinational enterprises (MNEs). However, as these assets gain importance and drive profits, they also come under increased scrutiny from tax authorities worldwide. Below we will further discuss the growing importance of intangibles in global transfer pricing, the challenges companies face in complying with tax regulations, and how transfer pricing documentation software, like TPGenie from Intra Pricing Solutions, can help MNEs manage these complexities and ensure compliance. The Growing Importance of Intangibles Intangible assets are central to the business models of many MNEs, especially those operating in high-value industries such as pharmaceuticals, technology, and media. Unlike physical assets, intangibles often lack a market price, are difficult to measure, and often drive a significant portion of a company’s profitability. This makes their valuation highly complex and often subjective. For MNEs, the transfer pricing of intangibles involves determining how these assets are priced when transferred between related entities across borders. Since these assets play a critical role in profit generation, tax authorities are closely scrutinizing their valuation to ensure that companies are not shifting profits to low-tax jurisdictions. This scrutiny has intensified in the wake of global initiatives such as the OECD’s Base Erosion and Profit Shifting (BEPS) project, particularly Actions 8-10, which focus on aligning transfer pricing outcomes with value creation. Key Challenges in Transfer Pricing of Intangibles Valuing and pricing intangibles for transfer pricing purposes presents several... --- The digital economy has fundamentally transformed global business landscapes, enabling companies to operate seamlessly across borders and leverage digital assets to drive growth and innovation. This rapid digitalization, while offering significant opportunities, also presents unique challenges for multinational enterprises (MNEs) in the realm of transfer pricing. As tax authorities intensify their focus on ensuring fair taxation in the digital economy, MNEs must adopt advanced tools and strategies to navigate these complexities. This blog explores the intersection of the digital economy and transfer pricing, highlighting how transfer pricing documentation software can aid MNEs in achieving compliance and managing risks. The Digital Economy: A New Paradigm The digital economy encompasses a broad spectrum of activities facilitated by digital technologies, including e-commerce, cloud computing, social media, online advertising, and the development and sale of digital content and services. Companies operating in this space often rely heavily on intangible assets such as intellectual property (IP), data, and software, which can be challenging to value and allocate appropriately across different jurisdictions. A specific example includes the global operations of e-commerce MNEs. These companies rely heavily on intangible assets such as its proprietary algorithms, customer data, and software infrastructure. These assets, which drive its recommendation systems, cloud services, and logistics optimization, are central to its business model. However, valuing these intangible assets and determining how much revenue or profit to allocate to different countries where the MNE operates (for tax purposes) is complex. This challenge arises because the value of intellectual property may be created in... --- We are proud to announce the release of TP Copilot, an AI-powered module now integrated into TPGenie, designed to check all documents generated by TPGenie thoroughly against the latest OECD Transfer Pricing Guidelines and local legislation. TP Copilot significantly reduces the risk of non-compliance. What is an AI Copilot? An AI copilot refers to an artificial intelligence system designed to assist and collaborate with users in performing specific tasks. Rather than fully automating processes, the copilot works alongside the user, offering suggestions, performing calculations, handling repetitive tasks, or providing insights based on large data sets. What is a Transfer Pricing Copilot in TPGenie? TP Copilot leverages artificial intelligence to assist users creating transfer pricing documentation that's is accurate and up-to-date. With its capability to interpret patterns and spot potential issues, TP Copilot is tailored for the unique challenges of transfer pricing, where accuracy, adherence to regulations, and consistency across documentation are crucial. Addressing the Challenges of Transfer Pricing Transfer pricing involves testing prices for transactions between related entities across different jurisdictions. This requires detailed documentation to meet both local regulations and international standards, such as the OECD guidelines. Manual handling of these processes can be time-consuming and prone to errors, especially as reporting requirements grow more stringent. How TP Copilot Transforms Transfer Pricing Workflows By automating the validation process, TP Copilot checks all documents thoroughly against the latest OECD Transfer Pricing Guidelines and the specific requirements of local legislation. The system is designed to enhance transparency and user confidence by... --- Global supply chain disruptions, inflationary pressures, geopolitical tensions, and global elections have emerged as significant challenges in the recent world economy. Supply chain disruptions caused by restricted trade routes, energy shortages, and sanctions, have led to rising transportation and input costs. Moreover, inflationary pressures fuelled by these crises are pushing prices higher across the globe. As multinational enterprises (MNEs) face this complex landscape, they need to strategically adjust their transfer pricing policies to remain compliant while mitigating the financial impact of these global challenges. Below we will further explore how the global conflicts, combined with inflation and political shifts, are affecting transfer pricing and offers insights into key strategic considerations for MNEs. Supply Chain Disruptions in a Nutshell For MNEs, transfer pricing—used to set prices for transactions between related entities in different jurisdictions—is closely tied to the stability of supply chains. When disruptions occur, MNEs can significantly alter the costs tied to intercompany transactions, impacting profit margins. As a result, businesses must continuously evaluate how these shifts affect their transfer pricing models to maintain compliance with the arm's length principle and ensure alignment with global tax regulations. Supply chain disruptions is nothing new, but since the onset of COVID-19, global supply chains have faced unprecedented disruptions, creating long-lasting ripple effects across industries. Lockdowns, factory closures, labour shortages, and restricted transportation routes initially caused severe delays and inventory shortages. As demand surged for certain goods, such as medical supplies and electronics, bottlenecks intensified, particularly in critical nodes like ports and shipping.... --- As environmental, social, and governance (ESG) factors continue to gain prominence in the global business landscape, multinational enterprises (MNEs) are increasingly integrating sustainability into their core strategies. Transfer pricing plays a crucial role in aligning business practices with ESG objectives. Let’s look further into this ever evolving field: ESG and Transfer Pricing: An Evolving Landscape Environmental, social, and governance (ESG) factors have become central to investment decisions, corporate governance, and regulatory compliance. Governments and regulatory bodies worldwide are tightening regulations to enforce ESG-related disclosures, carbon accounting, and sustainable business practices. As MNEs navigate this evolving landscape, transfer pricing becomes a strategic tool not only for tax compliance but also for achieving sustainability goals. Key elements in the evolving landscape of ESG and transfer pricing include: Carbon Cost Allocation, which ensures costs related to carbon taxes and cap-and-trade systems are allocated based on an entity's emissions and reduction efforts; ESG Return on Investment (ROI), which involves aligning transfer pricing methods with the actual returns on investments in sustainable technology, green infrastructure, and corporate social responsibility; and ESG Benchmarking in Transfer Pricing, which requires establishing arm’s length prices by incorporating ESG benchmarks and evaluating how comparable companies price ESG-related costs and benefits. Transfer pricing and ESG are closely linked through several channels: Sustainability-Linked Transfer Pricing Policies: Transfer pricing policies can incorporate sustainability objectives by incentivizing eco-friendly practices, enhancing resource efficiency, and aligning profits with sustainability-driven value creation. Impact on Value Chains and Cost Structures: Integrating ESG considerations into transfer pricing can lead... --- Last month marked an exciting chapter for Intra Pricing Solutions and TPGenie, our flagship Transfer Pricing Documentation solution. After months of hard work by our whole team, we proudly unveiled a complete visual overhaul, introducing a fresh and modern design that reflects our future direction. What’s New? The most noticeable change is the logo update. After many years, we said farewell to the lighthouse that had been a familiar symbol for our company. In its place, we introduced a sleek, abstract version of the TPGenie logo, now unified across both Intra Pricing Solutions and TPGenie. This new approach simplifies our branding and makes it easier for our community to recognise us at a glance. Alongside the logo, we’ve introduced a contemporary colour palette and modern fonts, designed to enhance the user experience. Importantly, the update focused solely on the visual aspect—there were no changes to the functionality. All menus, modules, and elements remain where you expect them, ensuring a seamless transition for users. Preparing for the Future Our goal with this redesign is to prepare both Intra Pricing Solutions and TPGenie for the future. The refreshed look supports our mission to offer an improved and more intuitive experience, enhancing efficiency in the creation of transfer pricing documentation. The transition was carried out smoothly, with no downtime during the software updates, and we are pleased to report that the response from our clients has been overwhelmingly positive. We are thrilled to see such enthusiastic reception to the new design. We want... --- The Pillar Two regulations, part of the OECD’s Global Anti-Base Erosion (GloBE) framework, require multinational enterprises to calculate and report global tax liabilities. With this, the need for Pillar Two software has emerged, designed to streamline the process of filing GloBE Information Returns (GIR). Pillar Two Software Pillar Two software solutions help multinational enterprises comply with GloBE rules, which aim to prevent profit shifting by ensuring a minimum effective tax rate across jurisdictions. These tools automate the data collection, calculation, and filing of tax reports, including essential elements such as: Message Headers: Details of the sender, recipient, and report type. Identification Numbers (TIN/ID): For constituent entities, parent companies, and tax filings. GloBE Body: Core tax calculations for each jurisdiction, including income, exclusions, and top-up tax computations. Why You Need Pillar Two Software Complying with Pillar Two regulations requires complex data management and precise reporting. Pillar Two software provides solutions to streamline this process by: Automating the collection of financial and tax data from multiple jurisdictions. Standardising reporting with the GloBE XML schema. Ensuring compliance with the OECD’s inclusive framework. As global tax reporting grows in complexity, Pillar Two software helps companies reduce errors, improve transparency, and meet their regulatory obligations efficiently. Features to Look for in Pillar Two Software When selecting a Pillar Two software solution, look for the following features: XML Schema Compliance: Ability to structure reports according to the OECD's XML schema. Automated Filing: Facilitates timely and accurate tax return submissions. Flexible Integration: Can be integrated with existing... --- Compliance with transfer pricing regulations across multiple countries presents a complex challenge for organizations operating and planning to expand internationally. This requires careful navigation in understanding diverse regulatory landscapes and meeting all the necessary deadlines. Intra Pricing Solutions offers an All-in-One Transfer Pricing Documentation Software called TPGenie, which specifically features a built-in compliance tracker. This tool empowers multinational companies to stay on top of diverse regulations and deadlines worldwide, providing them with valuable insights to streamline their operations effectively. The compliance tracker enables companies with the following: TPGenie’s automated calendar system Utilising the TPGenie compliance tracker streamlines transfer pricing compliance by integrating an automated calendar system. The tool automatically sends reminders and updates to the relevant users in the tool. This ensures timely reminders and updates for deadlines across jurisdictions, mitigating the risk of fines and suspicions of tax evasion. Proactive adherence to deadlines not only demonstrates diligence but also promotes operational efficiency, minimising errors and costly rework while fostering transparency with tax authorities. The compliance tracker provides country-specific transfer pricing requirements, including specific deadline dates, URLs for country portals and information on your companies transfer pricing status in meeting the deadlines. The compliance tracker provides generic data sourced from third-party resources. However, we offer a feature that allows you to overwrite this data with your group's specific information, tailoring it to meet your TP policy. For example, if your company has specific needs in Germany, you can input this information into the compliance tracker. Simply click on the field,... --- Over the last decade there has been a significant increase in the domain transfer pricing regulations and compliance requirements. The OECD’s Base Erosion and Profit Shifting (BEPS) initiative, have added layers of complexity, demanding more stringent documentation and reporting. Artificial intelligence (AI) and large language models (LLMs) hold the potential to meet the demand for consistent valuation and stringent regulatory requirements. An open-source, public-facing AI model that provides tax transparency and serves as a guiding light for multinational enterprises adhering to its valuations could be a game changer. AI in Documentation and Compliance AI can revolutionize the way companies handle transfer pricing documentation and compliance. Traditionally, this has been a labour-intensive process, requiring hours of gathering, analysing, and reporting of financial data. AI models, particularly those based on large language models (LLMs), can automate and streamline these tasks. Automated Data Extraction and Processing: AI can efficiently extract relevant data from various sources, including financial statements, tax returns, and inter-company agreements, reducing the risk of human error and ensuring the data is accurate. Consistent Documentation: By applying sophisticated algorithms, AI can ensure that documentation meets compliance standards across different jurisdictions. This includes preparing local files, master files, and country-by-country reports, essential components of the BEPS Action Plan. Real-Time Updates and Monitoring: AI tools can continuously monitor changes in regulations and update documentation requirements, accordingly, ensuring companies remain compliant and avoid penalties. AI in Benchmarking and Risk Management Benchmarking is a critical aspect of transfer pricing, involving the comparison of inter-company transactions... --- Transfer pricing is one of the most critical tax issues faced by multinational enterprises (MNEs) today. As regulatory scrutiny intensifies worldwide, ensuring that your transfer pricing documentation is both accurate and compliant has never been more important. For many MNEs, managing transfer pricing across multiple jurisdictions is a complex and resource-intensive task. This is where TPGenie, the leading transfer pricing SaaS solution, provides a transformative approach. The Transfer Pricing Challenges Faced by Multinational Enterprises MNEs operate in a highly complex environment where intercompany transactions span multiple jurisdictions, each with its own set of regulations and documentation requirements. The volume and complexity of these transactions, combined with the need to accurately allocate profits across different entities, make transfer pricing a formidable challenge. The increasing focus on transparency, driven by initiatives like OECD’s BEPS Action 13, has heightened the need for meticulous documentation. MNEs must now produce Master Files, Local Files, and Country-by-Country Reports (CbCR), all while ensuring that these documents are consistent and compliant with the latest international standards. Traditional manual processes are no longer sufficient to meet these demands. MNEs require a robust, scalable solution that can handle the complexities of transfer pricing documentation efficiently. This is where TPGenie, a specialised transfer pricing SaaS platform, offers a significant advantage. How TPGenie Simplifies Transfer Pricing for MNEs TPGenie is designed specifically for the needs of MNEs, providing a comprehensive transfer pricing SaaS solution that manages every aspect of transfer pricing documentation. Whether you operate centrally or have decentralised teams across the... --- In the coming month, TPGenie will undergo a significant visual update. After months of dedicated work, the team is ready to unveil a fresh design and new branding for TPGenie. This update aims to enhance user experience with a clearer, more modern interface. What’s Changing? The update to TPGenie will introduce new colours and fonts, providing a more streamlined and visually appealing experience. Importantly, there will be no changes to functionality. All menus, modules, and elements will remain in their current locations, ensuring that users can continue to navigate the platform with ease. Why the Update? The new design prepares TPGenie for the future, allowing for better service and efficiency in creating transfer pricing documentation and related tasks. The refreshed branding and interface align with the goal of offering an improved and more intuitive user experience. Support and Questions For any questions regarding the new design, users can reach out to us. The support team is ready to assist with any inquiries or concerns. Stay tuned for the rollout next month and experience the updated TPGenie, designed to better meet your needs in transfer pricing documentation. --- TPGenie, your trusted companion in writing and automating transfer pricing documentation, is ready for a transformative leap. After more than half a decade of steadfast service, our platform is evolving to meet the zeitgeist of the modern digital era. We're thrilled to announce a comprehensive restyling of TPGenie, set to launch at the end of Q2. Elevating TPGenie: Beyond Aesthetic Refinement This restyling is a reflection of our unwavering commitment to excellence and the embodiment of our vision for the future of transfer pricing software. It's a deliberate step towards not only enhancing the visual appeal and user interaction with TPGenie but also significantly amplifying its functionality and intuitiveness through the integration of Artificial Intelligence (AI). Anticipated Enhancements With this restyling, TPGenie is set to undergo a metamorphosis that promises to redefine the user experience: New Logo and Color Palette: Reflecting our forward-thinking ethos, our new visual identity is set to inspire. Sophisticated Interface Design: TPGenie will have a revamped interface that aligns with the latest trends in software usability and design. This new interface will prioritize clarity, making navigation and data management more intuitive for all users. AI-Powered Features: The integration of AI stands at the forefront of this evolution. TPGenie will harness the capabilities of artificial intelligence to offer predictive analytics, enhanced data analysis, and automated compliance checks, thus ensuring that your transfer pricing documentation processes are not only faster but also more accurate. Customised User Experience: Recognising the diverse needs of our users, TPGenie will offer increased... --- Say farewell to the time-consuming manual process and embrace a new era of precision and efficiency. Our AI-driven solution not only automates your benchmarking studies but provides an impressive 95% accuracy rate in filtering search results. Compatible with leading third-party databases, TPGenie offers seamless integration and a user-friendly interface that simplifies your workflow. Watch our latest video to see TPGenie Benchmarking AI in action, from uploading data extracts to applying AI for refined search results. Experience how our system intelligently matches financial data for arm’s length calculations and automatically translates and searches company websites for comprehensive analysis. Schedule a FREE TRIAL --- Welcome to the FAQ section for TPGenie Benchmarking AI, your comprehensive solution for transfer pricing studies. Below, you'll find detailed insights into how TPGenie integrates with databases and Excel files, its capabilities in financial analysis, market range calculations, and more. Discover how our AI-driven system streamlines the benchmarking process, enhances compliance with international guidelines, and delivers accurate, efficient results. Whether you're curious about the software's functionality, the extent of manual checks required, or the scalability of comparative analyses, you'll find the answers here. For any further inquiries or detailed information, our support team is readily available to assist you. 1. Integration with Databases and Excel Files TPGenie Benchmarking AI seamlessly integrates with both our proprietary databases and Excel files extracted from external benchmarking providers such as Orbis or D&B. Users can upload their Excel files directly into the system, which then intelligently matches the uploaded data. This ensures a smooth and efficient process for importing financial data for analysis. 2. Financial Information Extraction When utilizing our proprietary database, financial information is inherently included. However, for external benchmark extracts uploaded by users, financial information must be provided within the Excel file. 3. Market Range Calculation TPGenie Benchmarking module is designed to automatically calculate the arm's length market range, ensuring compliance with international transfer pricing guidelines and providing accurate market range calculations. 4. Current Assets Adjustments The system does currently not support adjustments to current assets within its functionalities. 5. Handling Database Entries without Websites In instances where a database entry lacks... --- Enter TPGenie Benchmarking AI, a solution that is revolutionizing how transfer pricing experts approach their benchmarking studies, enhancing accuracy, efficiency, and turnaround time for completing your transfer pricing benchmarking studies. 95% Accuracy in AI Decisions One of our clients recently shared their experience with TPGenie Benchmarking AI, and the results speak volumes about the platform's capabilities. In a detailed review where the AI results were ompared with a manual review, they agreed with a staggering 95% of the AI's decisions on whether a company should be accepted or rejected for benchmarking purposes. This level of agreement underscores the precision of TPGenie's AI, proving it to be an invaluable asset for finance professionals and companies worldwide. Exceptional AI-Generated Company Descriptions Moreover, our client found that in 84% of cases, the AI-generated company descriptions were spot-on. This was determined through manual comparisons with company websites. What's even more impressive is TPGenie's ability to read, understand, and translate websites in foreign languages, offering outputs in English. This feature alone opens up a world of possibilities, breaking down language barriers and ensuring comprehensive global coverage in benchmarking studies. Continuous Improvement and Precision While the feedback was overwhelmingly positive, it also highlighted areas for improvement, such as instances where the AI did not provide descriptions and automatically rejected companies. This constructive feedback is invaluable, as it drives us to continually refine and enhance TPGenie's AI capabilities. An example cited by our client of a mismatched company description has already prompted an in-depth review, showcasing our... --- TPGenie introduces the Upload External Benchmark feature, streamlining the process of importing and analysing transfer pricing benchmark data. This new tool facilitates a more efficient workflow by allowing users to easily upload their data extracts and select the relevant Excel tab for import. Next to the existing proprietary internal benchmarking databases, this new feature creates endless amount of opportunities for transfer pricing professionals who want to make use of third-party database providers, such as Orbis by Bureau Van Dijk or D&B. The platform automatically matches Excel columns to our internal database, enabling the inclusion of financial data for arm's length calculations. Once the data is imported, users are presented with an overview of the companies involved. As each entry is reviewed, TPGenie displays the calculated arm’s length range, assisting in the decision-making process. Key Features: Integration with TPGenie Benchmarking AI: Leveraging TPGenie Benchmarking AI, users can achieve a 95% accuracy rate in automatically accepting or rejecting search results, thereby increasing efficiency and reliability. Automatically calculates arm’s length range and PLIs: The Upload External Benchmark feature automates time-intensive processes within your transfer pricing benchmark practice, replacing redundant and repetitive tasks. Automated benchmarking writeups: The tool is designed to improve turnaround times, ensuring consistency, quality, and providing comprehensive audit trails. Improved Data Interaction: The feature enhances user interaction with data through the display of websites, which are shown, translated, and highlighted on a single screen for easier analysis. The Upload External Benchmark feature marks a significant advancement in transfer pricing benchmarking, offering... --- In the realm of transfer pricing, the challenges of standardisation and automation are paramount. With the introduction of TPGenie, a cutting-edge software designed to automate and standardise transfer pricing documentation, these challenges are not only met but overcome. This blog post explores the scope and benefits of implementing TPGenie, focusing on its potential to revolutionise the transfer pricing documentation process for tax managers and transfer pricing experts. Understanding the Core of TPGenie At its heart, TPGenie is engineered to recognise and process standardized transactions within a corporate group, enabling the automation of local file generation without necessitating year-on-year manual input for repetitive transactions. This recognition of standardization is crucial, as TPGenie's logic operates on the premise that the scope of transactions at the group level remains consistent, even if individual transactions at the legal entity level vary from year to year. The Value of Automation The implementation of TPGenie promises substantial efficiencies, particularly in time spent on file preparation. The software's capability to generate documentation automatically for a predefined set of standard transactions (T1 to T10, as examples) without additional user involvement is a testament to this. It is designed to accommodate changes or additions (such as T11 or T12 transactions) with minimal effort, requiring user intervention only for these exceptions. This not only reduces the manual workload but also ensures a high level of adaptability to the dynamic nature of business transactions. Simplification of Complex Cases Even in scenarios involving complex, unique transactions, TPGenie offers significant advantages. It provides... --- Supercharge your transfer pricing benchmarking with TPGenie's latest features: BenchmarkAI, our cutting-edge AI technology driven by OpenAI's ChatGPT revolutionizes the benchmarking process, saving you valuable time and ensuring precise results. Whether you prefer using TPGenie's proprietary benchmarking database or wish to upload external benchmark results from sources like TP Catalyst, Orbis, or any other benchmarking database, our software has got you covered. The search results can be swiftly processed through a combination of website crawling and AI, transforming raw data into actionable insights, allowing you to accept or reject them based on complex criteria. Forget the tedious manual sifting through results. TPGenie's BenchmarkAI scores and filters search results, automatically accepting or rejecting entries. The impact is impressive, weeding out irrelevant or subpar data swiftly. But that's not all – due to profound prompt engineering our system provides clear and concise explanations for the acceptance or rejection of each benchmarking result. How does it work? TPGenie crawls company names and websites, organising the information into structured text. This text is then scrutinised for comparable activities to your tested party, streamlining the benchmarking process. Refining your search is a breeze with TPGenie. Our smart AI prompts suggest multiple refinements, helping you tailor your benchmarking criteria effortlessly. Need to dig deeper? Apply additional pattern analysis, such as identifying similarities in results with for example an operating margin higher than % or dig in similar business activities. Key Features of BenchmarkAI: AI-powered automatic crawling of search result websites, transforming benchmarking search results into structured... --- In December 2022, The Republic of Moldova officially implemented its inaugural transfer pricing regulations, marking a significant development for businesses operating within the country. These regulations have been crafted in accordance with the guidelines set forth by the Organisation for Economic Co-operation and Development (OECD) on transfer pricing. It's important to note that these regulatory changes will take effect starting from January 1, 2024. What has changed? Moldova's Law No. 356, enacted on December 29, 2022, encompasses a series of fiscal and customs policy measures for 2023, with a notable focus on the implementation of a new transfer pricing regime. This development carries significant implications for multinational enterprises (MNE’s) operating in and from Moldova. The Moldovan government has set two materiality thresholds to be considered with regard to taxpayers that fall under transfer pricing requirements: Materiality Threshold 1: If your company conducts transactions with related parties, and the total annual value of these related-party transactions equals or exceeds MDL 20 million, you need to prepare and present information about these transactions as well as a transfer pricing file. However, you must provide this information and the transfer pricing file only upon request by the tax authorities. It's not mandatory to provide them proactively; you'll do so when asked by the tax authorities. Materiality Threshold 2: If your company engages in transactions with related parties, and the total annual value of these related-party transactions equals or exceeds MDL 50 million, there's a stricter requirement. In this case, you must prepare and... --- As transfer pricing-related tax audits become more prevalent, multinational companies (MNE’s) are facing heightened scrutiny in maintaining comprehensive audit trails for their financials and transfer pricing documentation. This surge in audits can be attributed to several factors and it is crucial for businesses to be prepared. For instance, MNE’s are being asked by tax authorities to provide transfer pricing documentation dating back to the fiscal year of 2019. When companies lack a robust audit trail regarding the financials in their transfer pricing documentation, defending the position and local files becomes a challenging task. Fortunately, TPGenie offers an array of audit trail features, including TP reconciliation and detailed change tracking. These features enable you to see who made changes, why those changes were made, and provide additional comments to provide essential metadata for defending your data alterations. Transfer Pricing audits likely to keep rising In our rapidly globalizing world, businesses are increasingly expanding their operations across borders. While this offers tremendous opportunities for growth, it also brings with it a heightened risk of transfer pricing issues. Tax authorities worldwide are taking more aggressive measures to combat tax avoidance and evasion, and one key area under their microscope is transfer pricing. Specifically, the Internal Revenue Service (IRS) in the United States has signalled its intent to allocate more resources to scrutinize the transfer pricing activities of multinational companies. Additionally, Luxembourg has experienced a surge in transfer pricing audits. These audits often concentrate on financial transactions, especially the terms of lending transactions and... --- The transfer pricing world is constantly evolving. The pace of change in the transfer pricing world appears to be accelerating because of commercial globalization and the OECD’s Base Erosion and Profit Sharing (BEPS) initiative. There are also growing resource challenges in the transfer pricing field stemming from the increased volume of work and the relatively limited number of qualified transfer pricing professionals. Against this backdrop there are several trends emerging. Some of the most notable trends include: Automation Technology is playing an increasingly important role in transfer pricing, as businesses look to automate and streamline their processes. Data analytics is also being used to gain more insights into intercompany transactions and the value created by MNE groups. With all the data available to companies, Data analytics is becoming increasingly important in transfer pricing, as it can be used to gain insights into intercompany transactions, benchmarking data, and tax positions. Products mainly focus on keeping records and files efficiently, and even these solutions take a substantial number of human work hours to implement and integrate with firms’ existing ERP systems. AI & Digitalization Technology solutions are advancing quickly to solve complex transfer pricing compliance problems. The digital economy is having a major impact on transfer pricing, as businesses look to adapt their pricing policies to reflect the new ways in which value is created and captured. This is leading to a greater focus on the use of intangibles, data, and other digital assets in transfer pricing analysis. Digital TP platforms are... --- In today's fast-paced business world, time is a valuable resource. We've been diligently observing our users and are delighted to share that our clients have reported spending over 50% less time on Transfer Pricing documentation over a period of three years by using TPGenie. Introducing the Time Comparison Graph Building on the insights gained from our users' experiences, we are excited to announce our latest feature - the Time Comparison Graph. This new addition on the TPGenie dashboard for Transfer Pricing managers, provides an intuitive and informative representation of the amount of time spent on reports using the Survey feature by local users over different fiscal years (FYs). Understanding the Graph The Time Comparison Graph showcases the evolution of time spent on reports over multiple fiscal years, aiding in the identification of consistent reductions in effort compared to previous year data. By analyzing this graph, users gain valuable insights into the efficiency and productivity improvements achieved in report generation over time. Graph Axes Y-Axis: Average Time per Report - The vertical axis represents the average time spent on each report. Higher bars indicate more time was required to complete reports during that specific fiscal year. X-Axis: Fiscal Years (FYs) - The horizontal axis displays the fiscal years, with each bar corresponding to a specific FY. This enables users to observe changes in time spent on reports over time. The number of reports is indicated when clicking the bar. Trend Line The Time Comparison Graph is enhanced with a trend line... --- A polished and professionally drafted transfer pricing policy document is a key ingredient in your compliance process. This could be a difficult process no matter if you are a CFO, transfer pricing manager, or junior pricing manager. We would like to share our knowledge and provide you with an example of a transfer pricing policy template. Below you can download a free Transfer Pricing Policy file template sample. You can use this example as a starting point for drafting your transfer pricing documentation. A transfer pricing policy template is a document that provides a framework for setting transfer pricing policies within an organization. Transfer pricing refers to the pricing of intercompany transactions that are taking place between related parties. A transfer pricing policy template includes guidelines for determining the appropriate transfer prices for commodity/service/financial/intellectual property transactions, as well as rules for documenting and reviewing. The template may also include information on how to deal with transfer pricing issues that arise, such as disputes with tax authorities. The template is a tool to help organisations ensure that their transfer pricing practices are following applicable tax laws and regulations while being consistent with the organisation’s key objectives. Download free Transfer pricing policy template Below you can download a framework of contents transfer pricing policy template. The file is generated with our software solution TPGenie Basic. The free Transfer Pricing documentation sample can be downloaded below. Download: Free Transfer pricing policy template TPGenie helps you generating a local file for your entity(ies) in... --- Environmental taxation and the treatment of carbon as part of an MNE’s value chain could be one of the most important trends alongside digitalization. Supporting this argument, the OECD has committed large amounts of resources in examining environmental taxes. The link between transfer pricing and carbon trading arises from the potential for companies to utilize their carbon emissions and carbon credit transactions in cost effective manners. This can be done through the strategic use of transfer pricing. Carbon trading in a nutshell Carbon trading is a market-based mechanism aimed at reducing greenhouse gas emissions. It involves the buying and selling of carbon credits, which represent the right to emit a certain amount of carbon dioxide or other greenhouse gases. The purpose of carbon trading is to create economic incentives for companies to reduce their emissions and promote the transition to a low-carbon economy. Under a carbon tax system, companies, industries, or individuals are required to pay a fee or tax based on the amount of carbon dioxide or greenhouse gases they emit. The tax is typically levied on fossil fuels such as coal, oil, and natural gas, which are major sources of carbon emissions. Governments often use the revenue generated from carbon taxes to fund climate change mitigation and adaptation measures, renewable energy projects, research and development in clean technologies, or to offset other taxes. Carbon taxation is a market-based approach to tackling climate change. By assigning a price to carbon emissions, it allows the market to determine the most... --- Inflation has been on an upward curve over the last few years and most central banks have followed with changing the monetary policy. The recent surges in interest rates and the volatility in the financial markets have changed the risk equation. This volatility causes transfer pricing risks to be under great attention as further changes may be expected in 2023. The higher interest rates however could also favour group arrangements from third party lenders, but this could lead to more complex arms-length considerations. By looking at the IMF forecast, there will be inflation changes around the world in 2023 that will continue to impact monetary policies. These changes have an impact on transfer pricing on various levels. One specific aspect is the effect it has on real estate portfolios in terms of loan agreements and transactions. Impact of high interest rates The oversimplified cause of high interest rates is the increased demand for money or credit. This changes the interest rates of transactions on real estate causing transfer pricing managers lots of extra work. It's worth noting that the specific impact of high interest rates on transfer pricing in real estate can vary depending on factors such as the specific transaction, the jurisdictions involved, and the overall economic conditions. The higher interest rate benchmark would imply that funding cost has risen. The adjustment in the cost of financing must ideally filter through to inter group funding arrangements. It is essential that the new market interest rates must be reflected in... --- In the beginning of 2022, the Ministry of Finance (MoF) of the United Arab Emirates declared that they would introduce Federal Corporate Tax (CT) on business profit. These changes were implemented in the financial year staring 1 June 2023. Traditionally the UAE tax system relied on the principles of territorial taxation, which means that taxation is generally applied to income derived within the country's borders. The UAE has further taken steps towards implementing transfer pricing regulations. The UAE Federal Tax Authority released on 9 December 2022 Federal Decree-Law No. 47 of 2022 (Taxation of Corporations and Businesses). That Decree-Law contains several articles relating to Transfer Pricing which are referred in these FAQs as The UAE Transfer Pricing Regulations. What are the major changes? The aim is to prevent MNE’s implementing tax avoiding strategies that includes transfer pricing manipulation. The UAE has committed to adopt Profit Shifting (BEPS) framework and Base Erosion as guided by the Organisation for Economic Co-operation and Development (OECD). The following articles is the central focus of the changes in the Decree-Law form in the UAE Transfer Pricing Regulations. Article 34 – Arm’s Length Principle Article 35 – Related Parties and Control Article 36 – Payments to Connected Persons Article 55 – Transfer Pricing Documentation What are the possible implications? The UAE Transfer Pricing Regulations introduced through Federal Decree-Law No. 47 of 2022 have several implications for MNE’s and transfer pricing managers and CFO’s will need to adapt to these changes: Compliance Requirements It will be essential... --- As a CFO or Global Head of Tax or Transfer Pricing expert working in a Brazilian multinational enterprise (MNE), you are likely aware of the challenges posed by transfer pricing regulations in Brazil. However, recent developments offer a glimmer of hope. The Brazilian Congress has approved new transfer pricing rules aligned with the OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This significant shift aims to bring Brazil in line with international standards, attract foreign investment, and eliminate past issues of misalignment and double taxation. The Impact of the New Legislation The new transfer pricing legislation marks a departure from Brazil's formulaic approach, replacing it with the arm's-length principle. By basing transfer prices on fair market values determined by transactions between unrelated parties, this principle ensures alignment with international standards. Additionally, the adoption of OECD guidelines will provide further clarity and consistency in transfer pricing practices. Opportunities and Risks for Brazilian MNEs This legislative change necessitates immediate action from Brazilian MNEs to adapt their business models to the new regulations. The impact will extend beyond corporate income tax to other indirect tax transactions. Consequently, transfer pricing methods and documentation requirements, particularly regarding intangible assets, business restructuring, and financial transactions, will require careful consideration. Compliance burdens will increase, and companies must align their transfer pricing policies with the OECD framework to mitigate risks. Introducing TPGenie - Simplifying Transfer Pricing Compliance To assist Brazilian MNEs in navigating these changes, Intra Pricing Solutions offers TPGenie, a comprehensive transfer pricing software solution.... --- Transfer pricing is undoubtably a key focus area in the international business community. Supply chain transformation, trade wars and regionalisation have created growing tax complexities. Multinational companies of all sizes need to constantly take steps to ensure that they are in a competitive position in this area. No matter how transparent the practices of a group are, the increased focus by all governments on transfer pricing increases scrutiny and possible audits. It is therefore crucial for all MNE’s to ensure that they have proper transfer pricing documentation (local file, master file and Country-by-Country Reporting, CbCR) in place. For many it is a struggle to compile TP documentation because of the complexity and the scale of the documentation. In general, many employees and legal entities across the world are involved in the process, while locally transfer pricing is unfortunately often viewed as a lesser priority. On a practical level we have seen organisations struggle by suffering from the uncontrollable process of Word-files being sent back and forth and excerpts from TP documentation manually being copy-pasted and shared via e-mail. This results in a high risk of non-compliance and not having all documents centrally in place in case of an audit. With increased scrutiny in cross border transactions its key to have a global transfer pricing strategy that effectively deals with the challenges of transfer pricing. This strategy is essential as transfer pricing includes accounting for services, intercompany financing, intangible valuation and their license, cost allocations, amongst other things. OECD reports A... --- In the past three decades, multinational companies have experienced no business function that grinds so deeply into all international operations as transfer pricing. Strategic decisions on transfer pricing have a large-scale impact on foreign operations of MNC’s, because it directly affects profits and global revenues. Growing international trade in intangible assets and e-commerce have made the documentation strategy essential, but tricky. Developing an effective transfer pricing documentation strategy is crucial for multinational companies to comply with tax regulations and minimise transfer pricing risks. The documentation strategy must have a clear explanation of the selected transfer pricing method, the data used and the application of the method to determine the arm's length prices. The detailed financial and non-financial information must also be included to demonstrate the accuracy of the pricing. There are two distinct ways in getting there and a combination of both approaches that might be the best solution. In the context of transfer pricing documentation, a centralised approach and a local approach refer to two different options to prepare and manage transfer pricing documentation within a multinational enterprise. Each of them come with their own benefits and drawbacks: Centralised Approach In a centralised approach, the responsibility for preparing and managing transfer pricing documentation rests primarily with the central or head office of the MNE. Information always flows through a central point. The dedicated central point contains all the required logic to execute a carry out the main documentation process. The central office takes the lead in formulating transfer pricing... --- Tax advisors can create transfer pricing documentation for their clients. By doing this they could add an additional service to the business that might unlock doors for future growth. Here are a few reasons why you can consider taking this route and some practical tips on the technology that will assist you in the process. Potential benefits for a tax advisor A successful tax advisor possesses a combination of knowledge, skills, and attributes that enable them to provide valuable tax-related guidance and services to their clients. We live in a world with a changing nature and advisors need to stay updated with the latest changes in tax legislation, while also possessing comprehensive knowledge of various tax codes, deductions, credits, and exemptions. With AI technologies helping to solve complex problems, the days are long gone where tax advisors can only rely on their own strong analytics capabilities in assessing the financial situations and strategies of clients. In working with highly confidential information its also important to adhere to professional ethics and confidentiality. Sound ethical process also builds your reputation in attracting clients. Creating transfer pricing documentation for your clients could further build your reputation within the industry. The major benefits include: Addressing the demand: The global focus on transfer pricing has significantly increased in recent years. Tax authorities around the world have tightened regulations and enforcement, making transfer pricing documentation a crucial compliance requirement for multinational enterprises. By offering these services, a tax advisor can align with market demand and assist... --- As of late tax technology have increased functionality and reporting capabilities for companies. These tax specific systems deliver a variety of methods to automate processes that brings many benefits. TPGenie from Intra Pricing Solutions offers companies a tax technology platform that guides them to meet transfer pricing obligations. Tax Tech in a nutshell Tax Tech, or Tax Technology, refers to the use of technology to streamline and automate tax-related tasks and processes. This can include tax preparation, filing, compliance, and reporting. It includes a wide range of technologies and software applications that assist individuals and businesses in managing their tax obligations. Tax Tech can be used for tasks such as tax preparation, filing, compliance, reporting, and audit support. Tax Tech solutions can also help reduce errors and increase efficiency, saving time and money for individuals and businesses. With the ever-changing tax laws and regulations, Tax Tech also enables businesses to stay compliant with tax requirements and avoid costly penalties. Tax Tech is basically the use of technology to enhance and improve various aspects of tax-related tasks and processes. Benefits of Tax Tech Tax tech offers several benefits to individuals and businesses. Here are some of the key benefits of tax tech: Increased efficiency: Tax tech can automate many tax-related tasks, reducing the time and effort required to complete them. This can help individuals and businesses to complete their tax obligations more quickly and accurately. Improved accuracy: Tax tech can help reduce errors in tax-related tasks, which can help individuals and... --- TPGenie, the innovative transfer pricing documentation tool, has just launched a game-changing feature: an AI writing assistant powered by ChatGPT. With this integration, TPGenie users now have access to an unparalleled level of writing assistance to help them identify conceptual and contextual inconsistencies, typos, grammar errors, and miscalculations. Transfer pricing documentation can be a tedious and time-consuming process, requiring a high level of precision and attention to detail. In addition to being technically challenging, the writing itself can also be a stumbling block for many practitioners. It can be difficult to maintain consistency in language and tone, while also ensuring that the content accurately reflects the complex economic reality of the transaction under review. With TPGenie's new AI writing assistant, users can now streamline the documentation process and eliminate errors, freeing up more time to focus on the analysis and strategic aspects of their work. ChatGPT is an advanced language model that has been trained on vast amounts of text data, enabling it to identify a wide range of errors and inconsistencies in writing. The integration of ChatGPT into TPGenie also means that users will have access to a more comprehensive suite of writing tools. For example, the AI writing assistant can help with everything from suggesting synonyms and sentence structure improvements to identifying common mistakes like subject-verb agreement errors and misplaced modifiers. Overall, the integration of ChatGPT into TPGenie represents a significant step forward in the field of transfer pricing documentation. With this new feature, TPGenie is poised to... --- When purchasing a transfer pricing documentation tool, there are several important success factors to consider. Reliability and accuracy The tool should provide accurate and reliable results. The calculations should be based on the latest transfer pricing rules and guidelines. The tool must be adaptable to the different regulations that countries impose. It’s essential to comply to the tax and language requirements of the country your business operates in. The tool must guide your company therefore to give accurate reflections based on the guideline of the country you operate in. User-friendliness A transfer pricing tool that is not user-friendly may not be utilized to its full potential, leading to delays, inaccuracies, and non-compliance issues. A transfer pricing tool that is user-friendly can increase engagement, save time and resources, and improve the overall success of transfer pricing projects. Customization The tool should allow for customization of the analysis to fit the user's specific needs. The user should be able to tailor the analysis to the specific transaction and company. The tool must among other things take charge in local file documentation for entities within a specific jurisdiction. It must also be able to generate a detailed comparability and functional analysis of the taxpayer and relevant associated enterprises with respect to each documented category of controlled transactions, including any changes compared to prior years. The tool must be able to generate information and allocation schedules showing how the financial data used in applying the transfer pricing method may be tied to the annual... --- Transfer pricing (TP) encompasses the rules and conditions that dictate transactions within a Multinational Enterprise (MNEs). Primarily it concerns the inter-company prices charged between associated enterprises in different jurisdictions. Therefore, transfer prices are the prices at which an enterprise transfers physical and intangible goods or services to an associated enterprise. The concept of associated enterprise is of focal importance in these practices. It covers direct or indirect participation in the management, control or capital of one enterprise in another enterprise in a different state or when the same person participates directly or indirectly in an enterprise's management, control or capital. Thus, TP can be deemed a crucial element of tax planning for MNEs since it directly affects the allocation of income and expenses among the different entities within a group, and the basis for taxation between two states. When it comes down to tax law, TP is based on the Arm’s Length Principle (ALP), which the Organization for Economic Cooperation and Development (OECD), has adopted in Article 9 of the OECD MTC. What is the Arm’s Length Principle? As stated by the OECD and the United Nations (UN), the principle of Arm's Length Principle (ALP) for TP has been the international standard for allocating taxable income among members of MNEs, and their Permanent Establishment (PE). In essence, the ALP treats members of an MNEs group as separate entities. This approach requires associated enterprises to conduct intra-group transactions, for tax law purposes, as if they were independent entities, thereby ensuring that... --- Transfer Pricing benchmarking studies require a considerable amount of data and information about the companies being compared. The more accurate and reliable the data, the better the benchmarking study's results. This is where ChatGPT from OpenAI comes in. ChatGPT can retrieve a wealth of information about companies, including their year of establishment, headcount, industry and company description. This information is critical for conducting benchmarking studies, as it helps to establish the comparability of the companies being compared. The year of establishment is an important piece of information that can provide insights into a company's maturity and the stage of its development. This information can help to establish the comparability of companies, as two companies that were established around the same time may face similar challenges and opportunities in their respective markets. Headcount is another crucial piece of information that can provide insights into a company's size and complexity. The headcount can be used to establish the comparability of companies, as two companies with similar headcounts may have similar organizational structures, which can impact their pricing decisions. Industry and company's description are another vital piece of information that can provide insights into a company's business activities and market position. The information can be used to establish the comparability of companies, as two companies operating in the same market with similar business activities may face similar challenges and opportunities, which can impact their pricing decisions. The data mentioned above is commonly presented in the "about" sections of corporate websites. Given that ChatGPT... --- TPGenie has made a significant leap towards automation and artificial intelligence by seamlessly incorporating ChatGPT - a state-of-the-art natural language generation system. Utilizing OpenAI's AI-powered technology, TPGenie can now produce natural language responses to transfer pricing-related queries, offering a more interactive and conversational user experience and reducing the time spent on creating Local Files and Master Files. By integrating ChatGPT in transfer pricing software, Intra Pricing Solutions sets TPGenie apart as the first-ever transfer pricing documentation tool to implement AI to this degree. Usage of ChatGPT in TPGenie The AI capabilities in TPGenie can assist you in different ways. Firstly, with an AI writing assistant powered by ChatGPT, TPGenie users now have access to an unparalleled level of writing assistance to help them identify conceptual and contextual inconsistencies, typos, grammar errors, and miscalculations. Secondly, in writing a description of functions, risks, and assets while preparing a Functional Analysis, and provide examples and guiding on how to do it correctly. The system can also retrieve summarised country-related data, making it easier for you to comply with local Transfer Pricing Regulations with minimum effort. Lastly, ChatGPT in transfer pricing software TPGenie can also improve the accuracy and relevance of additional information used in Local files or Master files. This new functionality acts as an additional writing assistant, helping you in formulating descriptions of functions, industries, MNE and company data. Additionally, ChatGPT is neatlessly integrated with the Transfer Pricing Benchmarking database, for retrieving additional company related information. You can read more about it... --- The Organisation for Economic Co-operation and Development (OECD) project on base erosion and profit sharing has caused an increased interest in transfer pricing regulations. The recommendations and guidance the OECD gives is interpreted by each nation, and this leads to different regulations in most countries. This leads to country specific transfer pricing regulations and makes it hard for multinational companies to comply with all the changes. Luckily the TPGenie tool from Intra Pricing Solutions offer country summaries for all relevant Organization for Economic Co-operation and Development (OECD) member countries. This is a great solution to the challenge of keeping up to date on the country specific regulations. Rules can reduce investment There has been an increased interest in transfer pricing regulations to mitigate tax avoidance by multinational companies due to the OECD project on base erosion and profit sharing. In 2018 Ruud De Mooij and Li Liu wrote an article on “The Real Effects of Transfer Pricing Regulations” in order to bring empirical evidence about the implications for investment into the conversation. They used data between 2006 and 2014 and used 27 countries as a sample group. In the study they used purely national companies as a control group, while looking at what effect transfer pricing changes had on investment in multinational companies. They tried to argue that transfer pricing regulation would only affect the cost of capital of the multinational affiliates. The results of the study were not that surprising. The introduction of transfer pricing regulations reduced investments in... --- Automation of your Transfer Pricing documentation process can be challenging exercise. The importance of data and the help it gives to ground facts, plans and strategies are undoubtably true in transfer pricing. Organising this data could be a headache as accounting and finance data could differ from tax data. A 2019 study by Ernst and Young showed that only 7% of companies in Germany, Austria and Switzerland make use of automated interfaces of connections to accounting systems. “Data really powers everything that we do. ” — Jeff Weiner Tax experts have been struggling with data collection for automating Transfer Pricing processes for many years. The data collection process for transfer pricing can be a painful process where documentation need to be inserted manually. This brings along inconsistencies and a constant planning process to steer profit along global value chain units. The transfer pricing documentation compliance requirements have also increased in complexity over the years. Main hurdles in automating your Transfer Pricing process Many multinational companies must overcome the hurdle of compliance and are looking for processes to streamline and centralise the documentation. In the past companies made use of local advisors that often-asked high fees and led to fragmented implementation as consistency lacked due to advisors doing the process different in different countries and industries. When multinational enterprises (MNE’s) do transactions, the key focus is on the price charged for products and services along the different business units. These amounts charged for interest, licenses, goods and services differ considerably between... --- TPGenie has a powerful tool that offers document formatting features to enhance the overall look and feel of outputted documents. With TPGenie, you can customize the margins, fonts, colors, tables, headers, and footers of your documents to match your company's corporate identity. With the built-in document previewer you can see the changes you make in real-time. Unification and consistency in your Document Formatting With the tool you can create a consistent and unified style that applies to all the documents you create with TPGenie. TPGenie offers a range of document template types that you can style, including Local File, Master File, Agreement, Benchmarking Comparable Companies, Benchmarking Interest Rate, Benchmarking Intermediary Financing Remuneration, Remuneration Benchmarking module, and Benchmarking Royalty. You can also copy, paste, or reset the styling for multiple document template types at once. The document styling section allows you to preview the changes in real-time as you make them. You can also edit the advanced header and footer by dividing it into three sections and inserting variables or logos. You can use variables in the header and footers. In addition to the header and footer, TPGenie also offers the ability to create a custom title page for your reports. You can upload a one-page Word document that contains the contents of your title page, including images and shapes. In conclusion, TPGenie offers a comprehensive solution for document styling, allowing you to create pixel-perfect documents that match your company's branding and identity. With the ability to edit advanced headers and... --- The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations were first implemented in 1995, with the intent to minimise conflicts between Multinational Enterprises (MNE) and Public Administrations in transactions involving Transfer Pricing (TP) around the world. More than 20 years later, in January of 2022, a new and updated version was published due to the rapid and unprecedented pace towards a digitalised economy and the fast-paced globalisation process. This latest version provides the revised version of the application of the profit method, the approach towards hard-to-value intangibles (HTVI) and considerations for financial transactions. Below you will find a summary of the OECD Transfer Pricing guidelines. OECD Tranfer Pricing Guidelines Chapters The guidelines provide a set of principles and methods that can be used to determine the arm's length price of a transaction. Members of the OECD adopted the arm's length principle in order to ensure the correct application of the separate entity approach to intra-group transactions. Even though they are not legally binding instruments, they have become the widely recognised international standard for transfer pricing. The guidelines are divided into ten chapters, each covering a focal part of Transfer Pricing. The first chapter introduces the Arm's Length Principle (ALP) and the application of this concept. The second chapter delves into the topic of transfer pricing methods. The selected method is crucial for determining the arm's-length price for a specific case, and it should be evaluated based on its strengths, weaknesses, and suitability in the particular case, as well... --- Transfer pricing software vs consultants are the two sought-after methods for managing the complexities of a multinational enterprise’s transfer pricing policy. The use of Transfer pricing software vs consultants comes with its own advantages and disadvantages. It is therefore important to figure out what works best for your business. The pros and cons of using TP software Most multinational enterprises (MNE’s) have structures that stretches beyond one geographical location. The operation between different locations and tax jurisdictions makes transfer pricing between units tricky to manage. The consultants and software must help companies in a variety of ways that could include advice around restructuring, plans to expand into new geographical regions, meeting compliance requirements from the authorities, needing more effective systems to manage transfer pricing etc. The lack of data on corporate taxation have been apparent. This has caused a major limitation in measuring the economic and fiscal effect of taxes. Authorities find it difficult to measure transfer pricing assessments of transactions happening between linked companies. The current legal requirements that multinational enterprises must meet calls for careful attention regarding preparation of Master file, Local files, Country-by-Country Report and supporting documents such as transfer pricing benchmarks and inter-company agreements. The bottom-line question companies must ask themselves in assessing their structure around transfer pricing is how they could meet the compliance requirements, while also having effective systems in place that can save time and money? Consultant and Transfer pricing software There are different routes to take in managing global transfer pricing. The... --- A challenging year We are fast approaching the end of a challenging 2022. We can approach 2023 with energy and zeal, but history have teached us that challenges are inevitable. The American financier and statesman Bernard Baruch famously said: “The art of living lies less in eliminating our troubles than in growing with them. ” The economic situation most companies and countries find themselves in is one where we need to deal with high inflation. The rise in inflation is mainly caused by the still concerning situation around the war in Ukraine, the rise in energy prices, rising consumer demand after the Covid-19 pandemic and supply chain issues stemming from the pandemic. Central banks around the world have countered with increasing benchmark interest rates. The implication of this counter directly influences intra group transactions. In the Netherlands the benchmark interest rate has climbed from around 0% in the beginning of 2022 to 2,5% at the end of the year. The benchmark interest rate in Netherlands (2022) Higher interest rate implications The recent surges in interest rates and the volatility in the financial markets have changed the risk equation. This volatility causes transfer pricing risks to be under great attention as further increases may be expected in 2023. The higher interest rates however could also favour group arrangements from third party lenders, but this could lead to more complex arms-length considerations. The higher interest rate benchmark would imply that funding cost has risen. The adjustment in the cost of financing must... --- Albert Einstein and taxes Taxes has throughout the ages been a major point of debate. Every country has their unique way of collecting taxes. Leo Mattersdorf was the tax advisor for Albert Einstein. They once had lunch together where Einstein famously told Mattersdorf with a chuckle: “The hardest thing in the world to understand is income taxes. ” Mattersdorf went on to say that Einstein’s relativity theory is much harder to grasp and I tend to agree with him, but this does not make the process of understanding taxes easy. On Monday 12 December 2022, The National Law Review released an article on the Dutch tax changes for 2023. There are some interesting changes regarding corporate income tax, real estate transfer tax and the energy investment allowance. The fiscal unity system however remains unchanged. What is a fiscal unity? One of the focal points of the Dutch corporate income tax system is the fiscal unity regime. Dutch tax resident companies can opt in to be included in the fiscal unity system. This implies that these companies are generally treated as one taxpayer. This is mainly done for corporate income tax purposes. The companies that can apply must have at least 95% of shares in a Dutch tax resident subsidiary company. When parent and subsidiary companies opt in for the fiscal unity, they are no longer independently responsible for corporate income tax, but they function as a fiscal unity meaning that they function as one taxpayer. An example: The Parent Company... --- TPGenie software is prepared to generate Country-by-Country Reporting Form 8975 and Schedules A (Form 8975), holding Tax Jurisdiction and Constituent Entity Information. You can use TPGenie to convert Excel to Form 8975 and bulk generate Form 8975 and Schedules A PDF-files. What is Form 8975? Form 8975 is used to report a U. S. MNE group’s income, taxes paid, and other indicators of economic activity on a country-by-country basis. The IRS will exchange Form 8975 information automatically with tax authorities with which the United States enters into a bilateral Competent Authority Arrangement. However, a U. S. MNE group’s information will only be exchanged with those countries in which the U. S. MNE group reports doing business. Form 8975 and Schedules A need to be attached to your income tax return and file them with the IRS by the due date (including extensions) for that income tax return. How does convert Excel to Form 8975 work? You can easily upload an Excel file holding your Country-by-Country Reporting data. Or you can collect the cbc data among your MNE entities by using our easy to use CbCR Survey. By the click of the button the system converts the cbc data to Form 8975 and it's schedules A. TPGenie automatically generates Form 8975 and a separate Schedule A for each tax jurisdiction in which your group has one or more constituent entities resident. A zip file holding the Form 8975 PDF files can be downloaded from the TPGenie Country-by-Country Reporting Module. It consists... --- TPGenie is prepared to flag for Public Country by Country Reporting. Public CbC will be in place for the MNE groups. To determine if an MNE is flagged for Public CbC, TPGenie uses the below set of rules: EU headquartered MNE and in last 2 years revenue > 750mil, or MNE group Outside EU and have medium or large size companies in the group. What is a medium / large size company? Companies that have in 2 consecutive years balance sheet 4 mil; net turnover of 8 mil; average 50 or more FTE. We also intend to build an export format with which the Public CbC can be published directly on the MNE website or in the annual report. --- Benchmarking study or comparability analysis is the heart of the application of the arm’s length principle. Application of the arm’s length principle is based on a comparison of the conditions in a controlled transaction with the conditions that would be applied between independent parties and undertaking a comparable transaction under comparable circumstances. Benchmarking study or comparability analysis is the process of identification of an arm’s length ranges (market level) of prices/margin in order to compare the prices/margin in the controlled transaction with such range. How to perform a Transfer Pricing benchmarking study A comparison implies examining two terms: the controlled transaction under review; the uncontrolled transactions that are regarded as potentially comparable. Below is a description of a typical process that can be followed when performing a comparability analysis (benchmarking study): Determination of years to be covered; Broad-based analysis of the taxpayer’s circumstances; Review the controlled transaction(s) under examination, in order to choose the tested party (where needed); Review of existing internal comparables, if any; Determination of available sources of information on external comparables where such external comparables are needed taking into account their relative reliability; Selection of the most appropriate transfer pricing method and, depending on the method, determination of the relevant financial indicator; Identification of potential comparables; Determination of and making comparability adjustments where appropriate; Interpretation and use of data collected, determination of the arm’s length remuneration. In practice, this process is not a linear one. Steps 5 to 7 in particular might need to be carried out... --- Intra Pricing Solutions BV is in the process of ISO 27001 certification. The goal is to receive the certification by the end of 2022. What is ISO 27001 Certification? ISO 27001 is an internationally recognised specification for an Information Security Management System, or ISMS. It's the only auditable standard that deals with the overall management of information security, rather than just which technical controls to implement (source). Update: december 2022 Intra Pricing Solutions obtained it's ISO 27001 certification. --- Multinational enterprises across the globe have to comply with transfer pricing documentation requirements. To provide the documentation which is fully compliant with tax legislation it should contain the calculation of arm’s length range – comparability analysis. In order to perform such analysis it is necessary to use one of the existing transfer pricing databases. This article shows an overview of most common transfer pricing benchmarking databases on the market. All databases can be divided into 3 types depending on the searching information: comparable companies (for sales of goods and intra-group services transactions); interest rates (for financial transactions); remuneration rates (for intangible transactions). Globally there are several providers of databases for each type: Comparable companies Orbis contains companies’ information across the globe. Database provide with profit and loss accounts and balance sheets; business overviews, industry codes and access to companies websites; ownership structures (including indirect ownership and beneficial owners). Amadeus – part of Orbis that contain information on companies across Europe. Royalty range – company financials database contains companies’ financials from P&L and balance sheets; companies website addresses and detailed companies descriptions; ownership charts showing connected entities. Thomson Reuters Onesource – company data contains public and private companies’ information, including financial statements, business segment content and industry description. Remuneration rates KtMINE contains aggregated repositories of IP data and documentation, including agreements, patents, trademarks, royalty rates. Thompson Reuters Onesource – intangible database provider of KtMINE’s licensing and royalty rate data. Royalty range – royalty rates database contains information on third-party license agreements,... --- As businesses continue to expand globally, transfer pricing has become an increasingly important topic for multinational enterprises. To assist companies in managing their transfer pricing policies, we have recently updated our transfer pricing software with a new feature: the Eastern Europe Transfer Pricing Benchmarking Database. Our Eastern Europe Transfer Pricing Benchmarking Database is a powerful tool that provides users with access to benchmarking data on transfer pricing practices in Eastern Europe. The database includes benchmarks for various industries and transaction types. With the Eastern Europe Transfer Pricing Benchmarking Database, users can quickly and easily compare their transfer pricing policies to those of their competitors and peers in the region. This can help companies ensure that their transfer pricing policies are in line with local regulations and best practices, and can also provide valuable insights into potential opportunities for cost savings and optimization. The database includes benchmarking data for a wide range of industries, including manufacturing, pharmaceuticals, retail, and more. Users can select their industry and transaction type to access relevant benchmarks and data points, and can filter the results by NACE, country, year, financials, and other variables. The Eastern Europe Transfer Pricing Benchmarking Database is a powerful addition to our transfer pricing software, and we are excited to offer this new feature to our users. With its comprehensive data and easy-to-use interface, the database can help companies ensure compliance with local regulations and optimize their transfer pricing policies to maximize profitability. Whether you are an experienced transfer pricing professional or... --- A transfer pricing policy template is a document that provides a framework for setting transfer pricing policies within an organization. Transfer pricing refers to the pricing of goods or services that are transferred between related parties, such as between different departments within a company or between a parent company and its subsidiary. The transfer pricing policy template typically includes guidelines for determining the appropriate transfer price for goods and services, as well as rules for documenting and reviewing transfer pricing transactions. The template may also include information on how to deal with transfer pricing issues that arise, such as disputes with tax authorities. Overall, a transfer pricing policy template is a tool to help organizations ensure that their transfer pricing practices are in compliance with applicable tax laws and regulations and are consistent with the organization's overall business objectives. Example of a Transfer Pricing Policy Template Purpose: This policy provides guidelines for determining the transfer price of goods and services transferred between related parties. Scope: This policy applies to all related party transactions, including those between parent and subsidiary companies, and between different departments within a company. Guidelines: Arm's Length Principle: All transfer pricing transactions should be conducted in accordance with the arm's length principle, which means that the transfer price should be set as if the transaction were between unrelated parties. Transfer Pricing Methods: The organization should use one or more of the following transfer pricing methods to determine the appropriate transfer price: Comparable Uncontrolled Price Method (CUP) Resale... --- When using TPGenie for creating local files for your MNE group entities, it could be that in some countries (for example India or China) you still have external tax advisors handling your transfer pricing documentation. How to deal with this in TPGenie? Is there a way to centrally store the files created by third party tax advisors in TPGenie? TPGenie allows you to upload files created by your external tax advisors. The uploaded files can be classified and can be indicated to overwrite the local file generated by TPGenie. Additionally you can set specific tags for each report to keep overview in the Report Management Dashboard whether the files were created externally and by which external party. The benefits are here that you have the flexibility of having external tax advisors, and all your files are stored in one central repository. The below step plan describes typical steps for indicating reports created by an external tax advisor: 1. Set the Tags for the Report Per report you can indicate specific tags. For example you can label the report with the tag EXTERNAL and the name of the tax advisor. This gives you a good indication that the report is handled by a third party. In the dashboards you can search and filter on specific tags so you can always see the reports created externally at a glance. 2. Upload the Local File manually You can upload the Local File created by the external tax advisor. When uploading the file you... --- Don't waste your time on sending back and forth Excels and lots of emails! TPGenie transfer pricing software is equipped with the CbCR Survey. The CbCR Survey is easy to use workflow software that enables you to gather your local CbC data across your group entities. On central level you can upload initial data such as entity details from your company book. On local level data is filled and/or confirmed. To gather data needed for Country-By-Country reporting the CbCR Survey delegates a number of questions to each of your local entities. The person locally responsible, such as financial controller, tax manager or CFO is guided through an intuitive step process to provide local CbC data. How does the CbCR Survey work? At every step you will be asked to provide the data or change the pre-filled data. Each step is confirmed by a save button to finalise the work, resulting in an audit trail being recorded. Steps can be rejected resulting in a conversation or the local actor can contact HQ in case of any uncertainty regarding accounting definitions or classifications. The steps are documented by help texts which informs the user about which input is required and the source of the pre-filled data. The CbCR survey is fully customisable up to the needs and procedures of your MNE. An example of steps included in the CbCR Survey are: Confirmation of data such as: Name of the entity Entity's address details Tax IDs Business Activities FTEs Other info such as... --- On April 21th 2021 the Dutch Tax Authorities released an update of specifications in the Country-by-Country Reporting Guide, version 4. 0. The overview includes new specifications and updated XML schemas for the Dutch CbCR XML delivery. From August 4th 2021 it is only possible to deliver CbCR XML Messages based on the new version 4. 0 specifications. We have updated the TPGenie CbCR Software Tool with these new specifications. In this article we would like to inform you about the changes we made in accordance with the Dutch updates. Changes in the Dutch Country-by-Country Reporting specifications v4. 0 A number of substantive changes have been made in the format of the Country-by-Country Reporting XML. The elements RelNr and UsedSoftwarePackage are made mandatory in the MessageSpec data group. The elements are identifying the software package used for the CbCR delivery. These identifiers were already in place from the very first beginning in 2017 and respectively needed to be filled in with the OSWO ID which is a unique identifier provided by the Dutch Government and name of the software package used to create the XML (in our case "TPGenie"). Elements ReportingPeriodStart and ReportingPeriod under MessageSpec data group are removed. This is a great example the Dutch were ahead of the game. In 2019 they added these elements in the MessageSpec section. In 2020 OECD followed by adding these elements as well, however under the ReportingEntity section in the XML. In the most recent version ReportingPeriod data group (with sub-elements StartDate and... --- Transfer pricing with respect to permanent establishments deserves separate attention. Whereas the OECD guidelines are primarily aimed at transactions between legal entities, the allocation of profits to permanent establishments requires a different approach. Here it is not so much about transactions between related entities, but about the allocation of profits to a permanent establishment which is part of a legal entity that carries out its activities in more than one country. It is desirable that both countries allocate profits equally to the permanent establishment. Obviously, this will not always be easy. Because what profit should be attributed to the activities of the permanent establishment? The Authorised OECD Approach The allocation of profits to the permanent establishment as described in the ‘Report on the Attribution of Profits to Permanent Establishments’ (PE Report) follows the so-called 'Authorised OECD Approach' (AOA). This approach aims to align the allocation of profits to a permanent establishment as closely as possible with the arm's-length principle as prescribed for a related legal entity (Article 9 OECD Model Convention and OECD Guidelines). In principle, it should not make any difference to a company's taxable profits whether its activities in a particular country are carried out through a legal entity or a permanent establishment. This approach means that, more than before, the so-called 'functionally separate entity approach' is explicitly chosen: each part of the company must be approached as a separate entity and must be rewarded in the same way as an unrelated entity would have been rewarded under... --- As of June 1, 2021, a new phenomenon came to stage: Public Country-by-Country Reporting. The key difference under this new regime is that much of the information from the CbC-reports would now become publicly available on the company’s website and on a central register. Since January 1, 2016, multinational companies with a turnover of €750 million or more are subject to a standardised documentation obligation: Country-by-Country (CbC) reporting. CbC-reporting is the implementation of action point 13 of the OECD Base Erosion and Profit Shifting (BEPS) project. According to CbC-reporting, the reporting entity of the multinational enterprise must submit an annual country report to the tax authorities in the country of which this entity is resident for tax purposes. The reporting entity is the ultimate parent entity, the surrogate parent entity, or another group entity. The country report contains information on, among other things: The profits made in the various tax jurisdictions; The turnover of affiliated and non-affiliated transactions; Taxes paid; The number of employees; The value of tangible assets; A description of the local activities. The Public Country-by-Country Directive The EU Member States have agreed on a draft law that obliges multinationals to disclose their profit figures and how much tax they pay in each European country where they operate. The rule should prevent tax avoidance. The European Commission's bill for more transparency on taxes dates back to 2016, but was blocked by a group of EU countries until a breakthrough was achieved in February 2021. As of June 1,... --- For a number of years now, tax authorities have been paying increasing attention to transfer pricing. But, how to set the correct transfer price? Transfer pricing involves determining arm's length transfer prices for transactions between related entities. In other words: any non-business elements must be eliminated for tax purposes. By adjusting the transfer prices to the prices that would be established between unrelated parties, it is ensured that the entire business profit is taxed. In determining transfer prices, the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the OECD Guidelines) play an important role. But, how to set the correct transfer price? The OECD describes the steps that can comprise the determination of the transfer price as follows: Step 1 Determining the period of analysis. Step 2 General analysis of the taxpayer's circumstances. Step 3 Analysis of the related transaction(s) based on the functional analysis to assess who will be the 'tested party' (if necessary), which transfer pricing method is appropriate, which financial indicator goes with it (in the case of a transactional profit method) and which comparability factors should be included in the analysis. Step 4 Assessment of potentially existing internal comparables. Step 5 Determination of the available information on external comparables with assessment of their relative reliability. Step 6 Selection of the most appropriate transfer pricing method and determination of the relevant financial indicator. This step is directly linked to the identification of comparables. To be specific, some of the main factors in choosing adequate transfer... --- TPGenie has been updated with Identity Access Management (IAM) features. IAM, also known as identity and access management (IAM or IdAM) is a framework of policies and technologies for ensuring that the right users (in an enterprise) have the appropriate access to TPGenie. IAM systems fall under the overarching umbrellas of IT security and data management. Identity and access management solutions have become more prevalent and critical in recent years as regulatory compliance requirements have become increasingly more rigorous and complex. The TPGenie IAM integration covers issues such as how users gain an identity, the roles and, sometimes, the permissions that identity grants, the protection of that identity and the technologies supporting that protection (e. g. , network protocols, digital certificates, passwords, etc. ). the features can be integrated neatly with Single Sign On, Two Factor Authentication, and more. IAM reads every night the status of users, roles and permissions from the enterprise's HR systems, and automatically updates TPGenie when changes are detected. For example when a user changes position or leaves the company. Are you interested in integrating IAM in your Transfer Pricing Documentation IT architecture? Contact Us! Contact us --- For many MNEs, transfer pricing is one of the major tax risks. This is because if an MNE and the tax authorities cannot agree on the arm's length price, this can result in fines or disputes. This is not only bad for the company's finances but also for its reputation. With this in mind, it is understandable that it is of utmost importance that the same transfer pricing policy is applied throughout the organisation. In short, what is operational transfer pricing? OTP is the management of transfer pricing policies throughout a MNE using technology. By effectively streamlining these policies, an OTP aligns transfer pricing requirements with commercial goals, thereby promoting compliance and reducing complexity. Background of operational transfer pricing In the past, MNEs used enterprise resource planning (ERP) systems. However, these systems were aimed at managing the company as a whole rather than specific legal entities. As a result, these systems proved less suitable for the transfer pricing process. Instead of these systems, manual processes were used to determine intercompany prices, for example. Companies were able to do so because there was enough time for it after the year-end closing. However, this is no longer the case in the current spirit of the times. Today, reporting to the tax authorities is almost in real time. In other words, the time one had to manually determine the intercompany prices has disappeared. In addition, the Base Erosion and Profit Shifting (BEPS) project is important. As a result, different tax authorities exchange more... --- Multinationals carry out activities in various countries with the aim of making a profit. The shareholders of multinationals are interested in the total, consolidated profit of the group in which they hold their shares. Where exactly this profit originates is generally irrelevant to them. For the tax authorities of the various countries in which multinationals carry out their activities, the situation is different. They want to levy tax on that part of the profit that is attributable to the activities of the multinational in question in their country. In practice, the determination of the profit (or loss) per country will not always be logically apparent from the administration of the multinational. In particular, if the financial organisation of the group is set up at divisional level and the various divisions are organised across national borders, the determination of the profit in relation to the divisional unit in a specific country can be complex. The tax authorities will try to match the profits of the legal entities established in their countries but will also encounter cross-border activities of these companies, possibly involving the establishment of a so-called permanent establishment in other countries. Given that the various tax authorities may tend to tax as large a proportion of the profits as possible and that double taxation is undesirable from an economic point of view, an internationally accepted method of distributing global profits is of great importance. In addition, an unequivocal application of the arm's-length principle can play a role in the starting... --- In this article we will explain what transfer pricing documentation entails. First, we will explain why you need transfer pricing documentation. Then we will briefly discuss the three different documents that are required. Finally, we will look at some other key elements. Why do we need transfer pricing documentation? Multinational entities (MNEs) nowadays have to keep a very extensive set of documentation. This is necessary to demonstrate to the tax authorities where they operate and that they comply with local legislation. If a MNE does not do this (properly), this can lead to fines, time-consuming discussions with tax authorities, or even lawsuits. Nowadays, transfer pricing laws require that transfer pricing documentation be maintained in almost all countries. In the past, each country had its own legislation for this, which varied considerably from country to country. This was the reason why, in 2011, the OECD paid attention to streamlining the documentation obligation for the first time. This eventually resulted in Action Point 13 of the BEPS action plan: 'Transfer Pricing Documentation and Country-by-Country Reporting'. As a result, countries agreed on minimum standards for standardised documentation requirements for MNEs. The standards developed have been implemented in national legislation of countries. The starting point is that the measures apply to fiscal years beginning on or after 1 January 2016. The report issued by the OECD as part of the BEPS project has also been reflected in the updated Chapter 5 of the Transfer Pricing Guidelines. According to section 5. 5, the three objectives... --- Multinational entities are able to optimise their profitability by restructuring functions, assets and risks. These are business restructurings in which specialisation and rationalisation are aimed at making operations more efficient. In this way, an attempt is made to achieve the economies of scale and synergy envisaged in mergers and acquisitions. Restructuring often involves the relocation of activities to other countries. Many tax authorities are critical of such restructuring operations because they see that this can be to the detriment of their own treasury. This is often a reason for taking active steps against them. The question is often whether, and to what extent, such restructurings should result in an exit tax in the country where the functions disappear, and whether some restructurings as such should not be ignored, if it is suspected that tax considerations are the main driver of a business restructuring. The OECD defines business restructurings as the cross-border reorganisation of commercial or financial relations between associated enterprises, including the termination or substantial renegotiation of existing arrangements. The main types of business restructurings that are distinguished are: Change from full-fledged distributors to limited risk distributors or commissioner, whereby a (foreign) associated enterprise will operate as a principal; Change from full-fledged manufacturers to contract manufacturers or toll manufacturers whereby a (foreign) associated enterprise acts as a principal; Transfers of intangible assets to a central entity (the so-called IP company) within the group; Concentration of functions in a regional unit with a concomitant reduction in locally performed functions. The arm's-length... --- Last months, we worked hard to integrate Adobe Sign capabilities into the TPGenie Intercompany Agreement Creation Module. The new integration substitutes the TPGenie Agreement workflow and uses the Adobe Sign process for adding e-Signatures to your intercompany agreements. These tools are part of Adobe Document Cloud, which includes all of the company's document management (DM) tools. The system includes: Full Adobe Sign integration, including workflow for signatures and validations Features to communicate with Adobe Sign API including sending and receiving documents Automatic e-mail notifications and reminders to the users Read status from Adobe Sign. Update the agreement status in TPGenie Read the most recent files from Adobe Sign. Update the file in TPGenie Show in the tool the signing URLS. Apart from the email a user receives, show in TPGenie direct links to the agreements in Adobe Sign Advantage of Adobe Sign vs. TPGenie e-Signatures Apart from the possibility to have a wet-ink signature, TPGenie has a native e-signature engine which is included with the intercompany agreement creation module. A digital signature can be uploaded to the user who is using the tool. When the user is selected as a signatory the digital signature is used in the contract. The integration of Adobe Sign has a few advantages in comparison to the native e-signature engine: Adobe Sign is a well-known e-Signature provider Signing of documents can be aligned with your corporate platform of choice All Adobe Sign features are included. Some of the useful features which are currently not available... --- A multinational entity (MNE) has its companies and activities located in (several) different countries. These ‘group companies’ often provide each other with goods and services within the MNE. However, national and international rules in the field of transfer pricing require group companies to trade with each other as if they are not related. The conditions of these trades are laid down in contracts, so-called intercompany agreements. In this article we briefly explain the importance of these intercompany agreements and how TPGenie can assist you in creating and managing your intercompany agreements. What are intercompany agreements? Intercompany agreements are arrangements made between two (or more) group entities that trade with each other. These agreements determine the conditions under which goods or services are delivered between group companies. Typical transaction types covered by intercompany agreements include: Head office and back office services (e. g. finance, tax, legal and HR services) Marketing services Intellectual property licenses IT services and support Revenue/profit sharing Cost sharing R&D services Contract manufacturing Toll manufacturing Shared services arrangements Sale of goods Sales agency and commissionaire arrangements Loan facilities (e. g. term loans, revolving credit and overdraft facilities) Intercompany debt in security form (e. g. loan notes) Guarantees and other forms of security or financial support Cash pooling Secondment of staff and other mobility arrangements Intercompany agreements vs. ‘regular’ agreements Intercompany agreements differ fundamentally from regular agreements. In regular agreements, two parties stand opposite each other, each representing their own interests. In such cases (lengthy) negotiations will take place... --- A professionally written local file is the key ingredient of your transfer pricing documentation. Whether you’re a CFO, transfer pricing manager or something in between, drafting a local file for your entity or group can be quite difficult. Transfer pricing local file requirements are described on the OECD website and you can find numerous great resources online on how to write a local file. Still, we get often the question about where and how to start. Therefore we are happy to share our knowledge and provide you with an example of the local file. Below you can download a free Transfer Pricing local file template sample. You can use this example as a starting point for drafting your transfer pricing documentation. The most common parts of a high-quality local file are described in this article. However, to make it even more complex, many countries have regulations slightly deviating from OECD guidelines. Countries such as Russia, Poland, Italy, to name a few as well as many Latin countries all implemented their rules slightly differently. Writing a local file for those countries need further investigation on the local regulations. Besides a local file, additional documentation is often required, such as benchmarks, Master File, Country-by-Country Reporting and intercompany agreements. Below you can download a table of contents transfer pricing local file in the format the OECD describes. The file is generated with our software solution TPGenie Basic. The structure is an example for an entity named and has four intercompany transactions included. The... --- A common question for transfer pricing advisors from their clients is: “How do I create compliant transfer pricing documentation? ”. The answer to this question is dependent on many facts. For example, the jurisdiction that is or jurisdictions that are applicable. Some countries may have more requirements than other countries. Some countries require to have the documentation available and other countries might require to actively submit documentation to the tax authorities. Some countries accept documentation in English and others only in the local language. Even the moments during the year when documentation needs to be available can differ from country to country. To give a basic overview of the various types of documentation the below provided guidance can serve as a good start to answer the question stated above. The guidance is ordered from documentation required in the most basic circumstances (for example a single intercompany transaction) to documentation required in more complex situations (for example a whole range of different intercompany transactions between many different group companies). Transfer pricing documentation can be grouped into four basic categories, from simple to more complex: Benchmarking documentation Local file documentation Master file documentation Country-by-country reporting documentation Requirements can differ per jurisdiction but in general (and as guidance provided by the OECD) the breakdown is the following: 1. Benchmarking documentation Benchmarking documentation is also known as economic analysis and is used to support the at arm’s length nature of the pricing of the intercompany transaction(s). The benchmarking documentation contains an analysis of the... --- In case your group or client has updated Country-by-Country Reporting (CbCR) information, a CbCR correction should be made. A reason for making a correction could be for example due to changes in the financial figures (Table 1), entity details (Table 2) or updates in comments (Table 3) resulting from mandatory corrections or errors in the previous provided information. The OECD advices to start exchanging the CbCR filings no later than 18 months after the last day of the that fiscal year (reference to section 3 of the "MULTILATERAL COMPETENT AUTHORITY AGREEMENT ON THE EXCHANGE OF COUNTRY-BY-COUNTRY REPORTS”). It is therefore advisable that corrections also should be made within this period. Technical complications creating CbCR correction The OECD has a complex correction system where multiple "corrections" can be made. A Country-by-Country Reporting (CbCR) correction can be made after an initial filing is done. In most cases, CbCR corrections refer to previous filings and/or "corrections". The system uses reference IDs in such way a "correction" refers to a previous filing. The OECD system is limited in such, that additions of data and updates of data cannot be sent in the same file. Therefore, if you want to add and update data, you will need to send two files to the tax authorities. A confusing side issue here is that addition of entities to present CbCR jurisdictions, this is seen as an “update” of the data instead of addition of data, due to the fact that the country-related details are “updated”. Many countries... --- TPGenie has powerful Country-by-Country Reporting features and CbCr services. Apart from features such as CbC data gathering, risk analysis based on KPIs and generation of CbCR XML, the software also directs you to the relevant tax authorities website for submission of your XML file. We found out the list can be very useful and we are happy to share it with the community! Below you find an overview of CbCR tax portal per country: Country CbCR filing portal URL Australia https://www. ato. gov. au/Business/Business-Portal/ Austria https://finanzonline. bmf. gv. at/fon/ Belgium https://eservices. minfin. fgov. be/myminfin-web/ Brazil https://santandertrade. com/en/portal/establish-overseas/brazil/tax-system Bulgaria https://nra. bg/page? id=319 Canada https://www. canada. ca/en/revenue-agency/services/e-services/e-services-businesses/corporation-internet-filing/software. html#P8_518 Czech Republic https://www. financnisprava. cz/en/e-tax France Must be filled using Electronic Data Interchange (EDI) procedures and format Germany https://www. bzst. de/SiteGlobals/Kontaktformulare/EN/CbCR/Data_sender_registration/kontakt_node. html Greece https://aeoi. aade. gr/aeoiapps/cbc-report/login/login. htm Hong Kong https://aeoi2. ird. gov. hk/cbc_portal/landing/ Indonesia https://djponline. pajak. go. id/account/login Ireland https://www. ros. ie/oidc/login/noCertsFound? lang=en&client_id=rosint_rp Japan https://www. e-tax. nta. go. jp/en/index. html Malaysia http://www. hasil. gov. my/bt_goindex. php? bt_kump=6&bt_skum=2&bt_posi=1&bt_unit=3&bt_sequ=1 Mexico https://www. sat. gob. mx/empresas/grupos Panama https://dgi. mef. gob. pa/_6IntercambioFiscal/Cbc. php Portugal https://www. portaldasfinancas. gov. pt/pt/ES/inicio. action Romania https://static. anaf. ro/static/10/Anaf/Declaratii_R/404. html Russia https://www. nalog. ru/eng/taxation_in_russia/nio/ Singapore via e-Mail Slovakia http://www. poreskauprava. gov. rs/en/E-taxes/Information. html South Africa https://www. sarsefiling. co. za/ Spain https://www. agenciatributaria. gob. es/AEAT. sede/en_gb/Inicio/Inicio. shtml Taiwan https://tax. nat. gov. tw/ United Kingdom https://www. gov. uk/log-in-register-hmrc-online-services Mauritius https://eservices3. mra. mu/cbcreporting/validatelogin Nigeria https://transferpricing. firs. gov. ng/login. php Senegal https://www. nra. gov. sl/tax-returns China http://www. chinatax. gov. cn/eng/c101270/c101275/index. html Pakistan https://www. fbr. gov. pk/automatic-exchange-of-information-portal/21227 Bahamas https://aeoi. portal.... --- When you are looking for purchasing the best transfer pricing software for your company, there are many considerations in making the right decision. When you compare transfer pricing software, one of the very important points to consider is to understand how much you are in control over the final outcome the software produces: your local files and master files. Lately, we have been talking to several new clients about their software selection process and their competitors analysis. We discovered that most TP software solutions offered on the market at this moment, produce very static transfer pricing documents. Static vs. dynamic generation of TP documentation When in need for a local file in a format that deviates from the standard OECD structure, it is impossible to generate the documentation using a "static software product" because the strict way the software is designed won't let you make changes in the output produced. When a tool generates static documentation you are in risk of generating piles of paper having duplicate texts. Even when you are in need for a simple local file for an entity without substantial activity. Additionally, software tools that are producing static documentation make you much more dependant on the knowledge of the software provider. When using a "dynamic software" you can create your own templates that deviate from the standard structure or even templates in different languages. In this case, you are not depending on software provider or specific advisor and free to make a choice whether do it... --- If you are responsible for performing the Country-by-Country Reporting for your group or as a tax advisor for your clients, you probably know that compiling your CbCR documentation can be quite a challenge. What many people don't know is that the technical part of creating a CbCR XML file is very hard too. Just to understand what steps are necessary to create a CbCR filing we describe the process to have an insight into the burden of manual steps to create a CbCR filing. The manual steps to create a CbCR filing Gather the data for the group. Structure the data in Excel by splitting it into the famous CbCR Table one and Table two. Performing risk analysis on the data and providing Table three comments. Creating the XML. Creating different versions of the XML for different countries. Sending the XML to the tax authorities. Below is a more in-depth description of the steps described above. 1. Gather the data for the group In an ideal world, the data required to comply with CbCR would reside in a tax-sensitized, group-wide ERP or consolidation system. In reality, such a system is still likely to be an aspiration for most Multinational Enterprises (MNE). The process and struggles of collecting the required data is another topic for a much broader article. Let's assume a MNE completed the first step and collected all necessary data for each company within the group. 2. Structure the data in Excel by splitting it into the famous CbCR... --- In many countries it is required to submit your Transfer Pricing documentation in a local language. This article provides you an overview of in which language countries require to submit Transfer Pricing documentation. Often it is required to translate Transfer Pricing documentation, for example by a certified translation service provider, however by using TPGenie you can translate your documentation automatically. Overview of required language per country In the below table you can see in which language you are required to submit to submit your local file, master file or Country-by-Country Reporting to local tax authorities: Country Language Algeria Arabic / French Austria English / German Belarus Russian Belgium English / French / Dutch / German Bosnia and Herzegovina English - The tax administration can request from the taxpayer to translate the documentation into local language. Brazil Portuguese/ Spanish / English Bulgaria Bulgarian Cambodia Cambodian / English Canada English / French Czech Republic Czech Egypt Arabic / English France French / English (translation may be required) Macedonia Macedonian Germany English / German Greece English Hong Kong English / Chinese Hungary Hungarian / English / German / French others may be requested for translation India English Indonesia Indonesian Ireland English Italy Italian Japan Japanese Kenya English Lebanon N/A Malaysia English / Bahasa Malaysia Mexico Spanish Mongolia TBD Mozambique Portuguese Netherlands Dutch / English New Zealand English Panama Spanish Papua New Guinea N/A Philippines N/A Poland Polish Portugal Portuguese Romania Romanian Russia Russian Serbia Serbian Singapore English Slovakia Slovakian / English (translation may... --- TPGenie was already for years equipped with functionality that allows reporting a fiscal unity (fiscale eenheid in Dutch) accurately. In our most recent software update of May 2020, we have improved the functionality to make it more versatile to the needs of various multinational companies and countries. Therefore we have improved flexibility by adding options to show, hide, or aggregate internal intercompany transactions. Learn More Group tax consolidation In principle a parent company and its subsidiaries in which the parent company has (directly or indirectly) 95% or more of the shares can create a fiscal unity for corporate income tax purposes. Under a fiscal unity, the parent company and its subsidiaries can file what is in effect a consolidated tax return after the necessary approval of the tax authorities has been granted. Although the tax is levied on the parent company, each member remains technically a separate taxpayer. In general, a fiscal unity is restricted to companies that are resident in the Netherlands on the basis of their place of effective management (and that are not resident outside the Netherlands under an applicable tax treaty or similar arrangement). Resident companies that are incorporated outside the Netherlands need to satisfy additional criteria (e. g. have a corporate form equivalent to Dutch companies). Subject to meeting certain conditions (e. g. as regards place of effective management, corporate characteristics et cetera), Dutch permanent establishments of non-resident companies may be included in a fiscal unity. A permanent establishment can also function as the parent... --- This week we organised TPGenie Users Day 2020 together with H&M. With our MNE key users we discussed the future of #transferpricing technology and potential roadmap for our software TPGenie. During the summit we discussed topics such as DAC6, TPForms and what the impact of these developments is on MNE’s. It was a blast! We learned a lot so we closed the day with a nice dinner. Thank you H&M for co-hosting and thank you everyone for joining! Soon we will reach out to our partners such as tax advisors for organising a similar event. Learn More --- We have worked hard to develop a new software product that takes the complicated process of performing an economic analysis / benchmarking study off your hands! As a tax advisor, MNE or Local Entity you can create your own benchmarks by making arm’s-length analyses for tangible and intangible intra-group transactions, intra-group services and intra-group financing. The tool eliminates the need to purchase data from external data providers and makes searching easier thanks to pre-selected results and direct integration with your #transferpricing documentation system TPGenie. The transfer pricing benchmarking software consists of four search engines. Each of them can be utilised for a different set of results: Comparable Companies in Europe and North America: Establish at arm’s-length remuneration using TNMM, Resale Minus and Cost Plus methods; Intermediary Financing Remuneration: Establish at arm’s-length remuneration for companies involved in Intermediary Financing and Cash Pooling activities using CUP method; Interest Rate: Establish at arm’s-length Interest Rate on Intercompany Loans using CUP method. The transfer pricing benchmarking software can be utilised in two different ways. Integrated: As a multinational or as a local entity. The results such as Benchmark Excel can be directly included in your Local file for your entity(ies). Standalone: As a tax advisor. The system creates a package of files such as write-ups and Benchmark Excel which can be be shared with your clients. The output can be fully customised to your needs including adding your corporate branding and company logo. Learn More --- Vanaf 4 juli 2018 moeten bij de Belastingdienst aangeleverde landenrapporten (Country-by-Country reporting / CbCR) voldoen aan de nieuwste versie 2. 0 specificaties. De rapporten op basis van de oude specificaties zullen vanaf die datum worden afgekeurd. De wijzigingen in versie 2. 0 vinden hun oorsprong in de known error list, welke tot stand is gekomen tijdens de eerste reeks van CbCR indieningen in december 2017 over het FY 2016. Opvallend is dat een aantal van de fouten die in deze update zijn opgelost door ons en onze software tools zijn geconstateerd. Wij hebben deze onvolkomenheden aan de Belastingdienst doorgegeven, waarna ze zijn opgenomen in de known error list. Het is interessant om te zien dat dankzij onze aandacht voor de kwaliteit van onze CbCR software tools de CbCR specificaties van de Belastingdienst konden worden verbeterd. Inmiddels hebben wij onze CbCR software tools aangepast aan deze laatste specificaties van de Belastingdienst en kunt u zorgeloos uw Country-by-Country reporting indienen met onze software tools zonder u zorgen te maken over de kwaliteit van de met onze CbCR software gegenereerde rapporten. Klik hier voor meer informatie over onze CbCR software tools. Meer informatie op de Country-byCountry Reporting sectie van de site van de Belastingdienst --- Multinationals are obliged to be in the possession of a list of ICAs (intercompany agreements), which serve as a supporting document to transfer pricing documentation and the tax position. TPGenie is recently updated with an inter-company agreements module. The module provides you with the ability to easily manage ICAs within a central environment in which creating or updating documents is made possible in a clear and efficient manner. The intercompany agreements module consists of the following functionality: A library containing all intercompany agreements where agreements can be uploaded and characterised by entering metadata. A dashboard displaying the overview of all available agreements where agreements can be uploaded and validated on a central level. For example by your legal department. Integration with with your transfer pricing workflow. Automatic notifications sent by email to inform counter parties and/or your legal department when information is updated or agreement’s due date is reached. Output generation of the package where agreements are identified and included in the final transfer pricing documentation. An overview of missing agreement, to quickly identify and mitigate potential risks. Why using the module? It provides the best overview for your intercompany agreements. You will know if one is missing or when they require updating. With your intercompany agreements module being compliant is a lot easier and reduces the risk of transfer pricing related penalties. No more spending a lot of time looking for the right intercompany agreement. The inter-company agreements module is easy to use. The inter-company agreements module is safe... --- TPGenie is now ready for the electronic transmission of your BEPS Action 13 Country-by-Country reporting XML file to the tax authorities in The Netherlands (Belastingdienst) using WUS 2. 0 Digikoppeling. As of January 1st, 2016, multinational groups with a turnover of EUR 750 million per year must report to the tax authorities on their profits, paid taxes, activities, etc. This is done by the use of a template developed by the OECD (OECD). Ultimately, this should result into an XML file containing data for all group’s companies that must be sent to the tax authorities. If the reporting entity of your multinational group has indicated to send the country report to the tax authorities in the Netherlands, you are required to transmit the file using the WUS 2. 0 Digipoort channel by Logius. In fact, this means that the Country-by-Country Report XML document must be packaged, electronically signed and sent to the Dutch tax authorities in a digital envelope. Logius and the tax authorities are ready to receive the country report starting week 40 (from October 2, 2017). Technically speaking, it appears that sending the file is quite difficult for multinationals. Therefore, we decided to update our TPGenie software solution with a specific module for sending your CbCr XML to the Dutch tax authorities. The module was developed based on information provided by the Dutch authorities Logius (provides EBV (Electronic communication with the Dutch authorities) for the tax authorities through ‘Digipoort’) and OSWO (Community Software Development to support software developers).... --- Our software solution TPGenie is ready for generating your BEPS Action 13 Country-by-Country reporting in the XML format according to specifications of the OECD and affiliated countries. It is a very user-friendly solution for converting Excel to CbCR XML. You can easily upload your Table 1, Table 2 and Table 3 data into the tool by uploading an Excel file. The tool performs some sanity checks and with one click of a button it is compiled into the correct XML Schema. Key features: Import your Country-by-Country reporting simply by uploading an Excel file. The tool has a useful overview section which provides information on issues and warnings related to the uploaded data. The tool performs sanity checks on the data and gives suggestions on entering additional Table 3 data. Corrections can easily be made with the tool before generating a valid XML file. Easily tagging additional information (Table 3 data) to jurisdiction, financial, legal entity or other information. Automatic exchange rate conversion. Upload Table 1 data in local currency and automatically convert it to your Reporting Entity’s functional currency. Automatic calculation and visualisation of tax ratios. This may be helpful to provide additional information regarding Table 3 and to map the risks involved. Export your Table 1, 2, 3 data to Excel for further analysis & country specific XML formats. In addition to creation of CbCR XML, TPGenie also provides options for sending your CbCR XML data to the Dutch tax authorities (Belastingdienst) using Digikoppeling (read more) and compiling other... --- Thursday, 7 September 2017 Time: 9. 00am – 4. 00pm Amsterdam (CET) Venue: Marriott Courtyard Amsterdam Airport Hotel In the post-BEPS era, a surge in the number of deadlines to meet has led to an increase in the compliance burden. This, coupled with escalating disputes in numerous locations across the globe, leaves limited opportunities for cost savings and tax optimization. In this light, many CFOs have indicated to TPA that they need to be on a path from ‘staying out of trouble’ to ‘being in control’. With this background in mind, it is crucial to increase efficiency of your organization through standardization and harmonization of processes, workflows and people. This can be efficiently executed only by automation through application of software solutions or by getting an “ERP on tax” fully implemented. However, depending on the business configurations, in-house organizational set-up, internal governance and compliance requirements, the applicable software solutions will vary considerably from one organization to the next. So, what is your tax technology plan for FY2017? Our Tax Technology Event will not only prepare your organization for delivering a ‘being in control’ statement to boards and audit committee but will also assist you getting started with your tax technology plan catered specifically to the requirements of your organization and people. During the workshop, the following topics will be covered: How to get your in-house organization and governance set-up BEPS-ready; How to implement technology solutions and change management; How to choose the most suitable tax technology solution. --- On February 1, 2017, the OECD released key documents, approved by the Inclusive Framework on BEPS, which will form the basis of the peer review of Action 13 Country-by-Country Reporting and for the peer review of the Action 5 transparency framework. The Action 13 standard on Country-by-Country Reporting and the Action 5 standard for the compulsory spontaneous exchange of information on tax rulings (the “transparency framework”) are two of the four BEPS minimum standards. Each of the four BEPS minimum standards is subject to peer review in order to ensure timely and accurate implementation and thus safeguard the level playing field. All members of the Inclusive Framework on BEPS commit to implementing the minimum standards and participating in the peer reviews. The documents released, form the basis on which the peer review processes will be undertaken. The compilations include the Terms of Reference which sets out the criteria for assessing the implementation of the minimum standard, and the Methodology which sets out the procedural mechanism by which jurisdictions will complete the peer review, including the process of collecting the relevant data, the preparation and approval of reports, the outputs of the review and the follow-up process. For more information about the peer review and monitoring process, please visit: BEPS Action 5: www. oecd. org/tax/beps/beps-action-5-peer-review-and-monitoring. htm BEPS Action 13: www. oecd. org/tax/beps/country-by-country-reporting. htm Source: OECD --- ---