Reptune

Exciting developments ahead 🚀🚀

𝗜𝘁'𝘀 𝘁𝗶𝗺𝗲 𝘁𝗼 𝘁𝗮𝗹𝗸 𝗮𝗯𝗼𝘂𝘁 𝗘𝗨 𝗽𝘂𝗯𝗹𝗶𝗰 𝗖𝗯𝗖𝗥. Let me guess. You heard somewhere that the deadline is generally the same as for non-public OECD CbCR, so those of you on calendar year will be filing by 31 December 2026. Plenty of time, right? 𝗪𝗿𝗼𝗻𝗴. Not only did Croatia and Romania jump the gun and implement the Directive early (triggering local filings), we now also have a deadline mismatch to grapple with, courtesy of 𝗦𝗽𝗮𝗶𝗻's implementation. 𝗧𝗵𝗲 𝗶𝘀𝘀𝘂𝗲: Although Spain transposed the EU Directive with a standard start date (impacting FYs starting June 22, 2024), they put in place a 6-month publication deadline instead of the default 12 months. 𝗪𝗵𝗼'𝘀 𝗶𝗺𝗽𝗮𝗰𝘁𝗲𝗱? Spain-headquartered groups and non-EU groups. EU groups (other than Spanish ones) file where they are based and follow home-country rules. 𝗧𝗵𝗲 𝘁𝗿𝗮𝗽 𝗳𝗼𝗿 𝗻𝗼𝗻-𝗘𝗨 𝗴𝗿𝗼𝘂𝗽𝘀: Even if you choose a "filing hub" in another EU country (say, Ireland), you can't escape Spain's 6-month deadline. The filing hub exemption only works if the parent's report is already published. But Spain's local deadline hits at Month 6—before your hub country's Month 12 deadline. At Month 6, the exemption conditions aren't met, so your Spanish subsidiary is technically in breach. 𝗘𝘅𝗮𝗺𝗽𝗹𝗲: You're a US-based MNE with a qualifying Spanish subsidiary on a calendar year. You'll have to publish your EU pCbCR by 30 June 2026 - not December. The deadline is painfully short. Consolidated financials are rarely ready by then, forcing groups to accelerate data collection, rush audits, or risk penalties. National Foreign Trade Council, a US trade body, has already written to the Spanish government complaining about unequal treatment. How Spain will react is anyone's guess. If anyone in my network has some intel, please share. NFTC letter: https://lnkd.in/d8heqt8W

As global transfer pricing reporting requirements continue to expand, the UK has taken a significant step forward. David Zářecký breaks down the new compliance landscape and what businesses should be thinking about next. 📝 Read more here: https://lnkd.in/e5wfF-cG

Things have definitely changed in the last 16 months at Reptune. With support from our investor, Vortex Capital Partners, and our new colleagues, we have significantly improved our processes, allowing us to offer better #transferpricing solutions to more clients. I am very excited to see that these new processes, allow our team members to focus more on what they excel in. At Reptune, we have an entire generation of power ladies that are challenging the way we've worked at Reptune in the last decade, and that are helping Reptune making transfer pricing even easier for our clients. 🚀 Today, I want to put the spotlight on three of them. In order of appearance, we have Mariel Cima, making sure we provide the best services to our clients; Maria Grigoryeva, translating the needs of our clients into great Reptune.net features; and Mariia Minchenko, making more companies enthusiastic about Reptune's end-to-end transfer pricing services. This is a shout-out to the great work done by Reptune's 3 M's. Can't wait to see what they have in store for us in 2026! 🫶

When you move from consulting to an in-house role, you quickly realise — there is a difference! 😅 For me, the biggest challenge was adapting my mindset (and language) from “it depends” to “this is what we should do.” Balancing TP compliance with the constant stream of urgent business requests also took some serious focus. And as you can probably guess, that’s when I began looking for a better solution. 👀 I decided to automate our TP documentation and prepare it in-house — and that’s how I met Lennart at Reptune. After exploring various tools and running a trial, I was convinced that Reptune was the best solution for us. 💡 That’s where my Reptune story began. From a customer, I became an ambassador — sharing my experience with colleagues, some of whom are now happy clients. 💬 From an ambassador, with a short break to welcome a baby, I became part of the Reptune team, helping clients implement the solution. The more I spoke with prospects, the more I realised that my journey placed me in a unique position to guide them in choosing their TP solution. 🤝 So here I am in 2026, taking an active role in introducing Reptune to new clients. I may not be a salesperson, but as my friends often say, I’m really good at sharing my enthusiasm for something I truly believe in. ❤️ 💬 Send me a message if you’d like to hear why I think Reptune is the best TP documentation software out there!

We’re proud to be sponsoring Uniglobal’s 11th Annual Corporate Tax & Transfer Pricing Summit! Join us in Frankfurt on 24-25 February for some insightful sessions and a chance to check out new developments in the transfer pricing space✨

No, it's not a typo. 🤓 As #transferpricing compliance is a core part of our daily work at Reptune, a large part of our focus is on the previous financial year. ⏪ Our clients are now working to finalise any remaining Local Files for 2024 and are initiating the 2025 TP documentation process. This particularly includes: ➡️ Preparing for the Master File update ➡️ Confirming changes in Local File scope ➡️ Confirming changes in local form scope ➡️ Planning for data gathering ➡️ Planning and prioritising Master File, Local Files, and local forms Over the last 10 years it has become clear that taking a proactive approach to TP documentation immediately after the financial year pays off. It reduces last-minute preparation efforts in countries with proactive filing requirements, and ensure data availability in countries that only require TP documentation upon request. Our clients use our proprietary TP documentation solution, Reptune.tax, to automate this process end-to-end. It's not too late to automate your TP documentation process for 2025 with reptune.net. 🚀 Interested to know more? Visit reptune.tax or reach out at [email protected]. 💻

Ever wondered how Dutch folks commute if the weather does not allow to cycle? Well, here's your answer. ⬇️ 2026 has started like it's still Christmas, but our team at Reptune has already kick-started the automation of global #transferpricing documentation for 2025. 📚

Happy new year to my network! The first TP update of 2026 takes us to India to a transfer pricing case involving Shell, an oil & gas giant, in a dispute with local tax administration over whether technical services can be provided at cost or require a mark-up. 𝗦𝗶𝘁𝘂𝗮𝘁𝗶𝗼𝗻 The Shell subsidiary in India implemented "at-cost" (no mark-up) TP for technical services provided to related companies in upstream oil and gas operations. These specialized services - covering geological and reservoir engineering - were rendered under Production Sharing Contracts (PSCs) that explicitly prohibit profit margins. Other consortium members similarly charged and received such services strictly at cost, establishing this as the industry norm. 𝗪𝗲 𝗿𝗲𝗮𝗹𝗹𝘆 𝘄𝗮𝗻𝘁 𝘆𝗼𝘂 𝘁𝗼 𝘁𝗮𝘅 𝘁𝗵𝗮𝘁 𝗳𝗮𝘁 𝗱𝗼𝘂𝗯𝗹𝗲-𝗱𝗶𝗴𝗶𝘁 𝗺𝗮𝗿𝗸-𝘂𝗽, 𝘁𝗵𝗮𝗻𝗸 𝘆𝗼𝘂 Indian tax authorities (ITA) rejected Shell's approach and applied a 16.52% mark-up, treating the highly specialized E&P services as comparable to standard IT/ITeS functions. ITA benchmarked using generic comparables without analyzing the fundamental differences in functions, risks, and market conditions, or acknowledging the contractual restrictions embedded in the PSC framework. The Dispute Resolution Panel upheld this adjustment, citing consistency with prior years and the Revenue's standard position. 𝗟𝗮𝘄 𝗽𝗿𝗼𝗵𝗶𝗯𝗶𝘁𝗶𝗼𝗻 𝗼𝗻 𝗺𝗮𝗿𝗸-𝘂𝗽𝘀 𝗮𝗻𝗱 𝗖𝗨𝗣𝘀 𝗮𝗿𝗲 𝘁𝘄𝗼 𝗽𝗼𝘄𝗲𝗿𝗳𝘂𝗹 𝘄𝗲𝗮𝗽𝗼𝗻𝘀 The Mumbai Tribunal sided with Shell, accepting that the services should be provided at cost. The ruling emphasized that TP provisions cannot ignore the commercial and legal framework governing such transactions, particularly where PSC terms prohibit mark-ups. The Tribunal validated Shell's use of the "Other Method" under Rule 10AB, supported by evidence that other consortium members followed identical "at-cost" practices and by an independent expert opinion confirming alignment with OECD guidelines and Indian TP regulations. The Tribunal criticized the Revenue for failing to strive for coherence when similar facts had been accepted at arm's length for other consortium members. 𝗧𝗵𝗲 𝗟𝗲𝘀𝘀𝗼𝗻 Sometimes, standard TP is overridden by regulations which prohibit a profit element or even the rendering of a supply. The practices how to treat such a situation differ – should you just accept it (as the Mumbai Tribunal did) and not attempt to ‘enforce’ an arm’s length principle through other means (say a tax return-only TP adjustment if money can’t be moved around)? This is one of those 50/50 TP situations. What may have tilted the decision in this specific case is that other consortium members (third parties) also used at-cost schemes, which constituted an incontrovertible CUP. A straightforward conclusion here – though many other situations won't be as clear-cut. Source: https://lnkd.in/dWku2NZi

Being a remote-friendly team means we don’t always get to celebrate every occasion all together, but we still make it count. Last night, our teams in the Netherlands and Argentina held their own Christmas dinners, taking time to reflect on 2025 and share excitement for 2026. 2025 marked Reptune’s 10-year anniversary and was a significant year for us. We welcomed many new faces, reimagined key processes, and raised the bar on what we can achieve together across the Netherlands, Argentina, and Sri Lanka. We’re heading into 2026 with positive energy, learning from both successes and setbacks, and always grateful for the people behind the progress. 🙏🏽🚀