Harmonisation of the efforts to discourage tax avoidance in the EU
Recently, besides the objective of maintaining a balanced allocation1 (a reflection of the principle of territoriality), the…
The attribution of profits to a permanent establishment is already a complex issue with at least three separate regimes in the tax treaty context- the OECD Authorised Approach under the 2010 OECD…
On June 27, 2016 the EU Commission published the long awaited Starbucks State Aid decision (see here). The EU Commission’s decision challenges the outcome of the Advanced Pricing Agreement (APA)…
“Improper and plainly undermines legal certainty and the rule of law.” This is how four U.S. senators – including the Chairman and Ranking Member of the U.S. Senate Finance Committee – recently…
The EU Commission and EU Parliament want to settle for nothing less than public country-by-country-reporting, in direct conflict with G20 BEPS adoption resolution. For many good reasons, business in…
On 6 June 2016, the European Commission finally released its decision in the McDonald’s State Aid case. After the clarifications recently provided on the Commission’s position concerning transfer…
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…
In highly dramatic fashion the French tax authorities and IT specialists raided Google's headquarters and McDonalds. I don't own Google stock. I'm not in favor of Google's near monopoly on search …
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…
