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
- Issue 01 · September 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.
On sources
Every factual claim in this letter names a primary source — the document, the judgment, the official register — and that source is read in full before the claim is written. 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.