Substance is a measurement,
not a narrative.
A weekly letter on transfer pricing, economic substance and valuation — written by an auditor who has to sign the file. One long piece, then what actually changed at the OECD, in the courts, and across jurisdictions.
Every issue, once a week
Transfer pricing, economic substance and valuation. One long piece, then what moved at the OECD, in the courts, and across jurisdictions — each item with its primary source.
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Issues
- 02September 2026Fewer files, closer readingDenmark has narrowed who must prepare transfer pricing documentation, and Canada has consulted on doing the same. Read together, that is not deregulation — it is a decision about where an administration spends its attention.Read the issue
- 01September 2026Paying the lawyers is not protecting the assetWhere the protection function actually sits when the valuable intangible is software — and why the entity that owns the asset usually cannot protect it.Read the issue
On sources
Every factual claim in this letter names a primary source — the document, the judgment, the official register — and the passage the claim rests on is read there, not in a summary of it. Where only part of a long document has been read, the claim stays inside that part. Secondary commentary is used to find things, never to assert them.
Where a source could not be obtained, the letter says so rather than working around it. An empty section is a result. A confident section without a source would not be.