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In quantum physics, nothing is certain, particles are not to be found at one point but within waves of probabilities and connected particles can mirror each other faster than the speed of light…

There are several misconceptions in international taxation, some of them more pervasive than others.  Many are often repeated by speakers at tax conferences without being contradicted. The first is…

There are many things in life that we take for certainties, which are not, e.g. that it was the Scots that invented whiskey, the French champagne, or the Italians pizza.  All not necessarily true…

This has been an interesting session and for those who were not there, I am sure that the essence is reported elsewhere in the international tax press.  The deliberations lead me to the following…

Random thoughts on presumptions on accuracy It is a fact that most in-house tax professionals know very little about their group’s financial systems.  E.g. very few know whether their companies…

I want to talk about TP documentation. If what I say seems a little crazy, then at least of part of it is to be deliberately provocative. I attended a wonderful TP conference in London in March with…

This is the first part of a series about numbers in transfer pricing. In this edition, I look at sticking the TP five methods on a typical profit and loss account (hereafter “P&L”). I find it curious…

(“Every in-house tax department should have their own IT/Financial systems capacity” – JHM, TP Minds London, 2015.) The unexpected benefit from country by reporting (“CbyC”) reporting is that tax…

Introduction It has been a few weeks now since the Commission has made public its decisions in the FIAT and Starbucks cases.  I understand that the Commission, the countries involved and the…