A Simplified Guide to Transfer Pricing Challenges Associated with Cash Pooling

by Cyrano | Mar 20, 2024 | Transfer Pricing

Tp qube With the rise in interest rates since 2022 and the release of revised OCED Transfer Pricing Guidelines in 2022 including new cash pooling recommendations, we believe this is the right moment to publish this simplified guide on transfer pricing issues raised by...

Tool – Evaluate the risk for not updating a benchmark

by Cyrano | Sep 1, 2023 | Benchmarks, TNMM/CPM, Transfer Pricing

Tool – Evaluate the risk for not updating a benchmark Following our article that provides some estimates of the likelihood of being out of the range in case of a TNMM benchmark update, we are happy to release a tool that estimate this probability based on a...

How to perform a comparable company search in Africa?

by Cyrano | Aug 24, 2023 | Benchmarks, TNMM/CPM, Transfer Pricing

Tp qube Transfer pricing policies of MNEs are more scrutinized than ever by tax administrations. African tax administrations are no exception. Hence, 28 African countries have joined the inclusive framework on BEPS[1]. MNEs have to secure their intragroup transaction...

AI + TP – Automatically pre-filling rejection matrices TNMM/CPM benchmarks thanks to AI – and why human expertise will still be necessary

by Cyrano | Jun 22, 2023 | Transfer Pricing

Tp qube We are (very) excited to share that we’ve reached a pivotal milestone in transfer pricing economic analysis. We unveil today a groundbreaking tool that leverages the power of Artificial Intelligence to perform TNMM benchmarks with an unprecedented level of...

The Importance of Regular Updates for TNMM/CPM Benchmarks

by Cyrano | May 9, 2023 | Transfer Pricing

Tp qube [UPDATED] We did the math! 🤓 🧮 A tool to get estimations related to a specific benchmark is now available ! Follow the link. Regular updates are crucial for TNMM / CPM benchmarks. The OECD recommends updating database searches every three years, while updating...

A simplified guide to intragroup loans [Update 2025]

by Cyrano | Apr 2, 2023 | Transfer Pricing

Tp qube Welcome to our article on a crucial transfer pricing issue: intragroup loans. Intragroup loans raise significant transfer pricing concerns, and, in this article, we will explore the following questions: 1. Back to basics, what are intragroup loans? 2. What are...