Transfer Pricing

“Those who cannot remember the past are condemned to repeat it” George Santayana, The Life of Reason: Reason in Common Sense (1905). A seminar was held in Rotterdam on 18 May 2018 on “value creation”…

Introduction As the General Reporter for the Subject 2 (The Future of Transfer Pricing) of the 2017 IFA Congress in Rio de Janeiro, I joined the plenary session on August 29 in a panel chaired by…

Increased focus on taxation of cross-border situations involving both individuals and companies is one of the key features of the post-BEPS international tax environment. One central aspect of this…

Introduction The financial crisis had made multinational enterprises (MNE) look inward for funding options, as external sources of capital were not readily available. Among various intra group…

It is 30 December and 2 MNEs contact me about my YouTube videos on uploading Country by Country Reports (CbCRs); they need help.  In the week of New Year, I helped taxpayers in Bermuda, Belgium,…

Taxation of the digital economy featured in discussion on the implementation of the OECD/G20 BEPS action items at the annual conference of the Canadian Tax Foundation in Toronto on 21 November 2017…

The problem “Please tell me what the header is, I don’t know what the namespace for multiple schemas should be.”  It seemed like a reasonable question, but I never got the answer.  The same fate…

Adoption of the EU Council Directive on Tax Dispute Resolution Mechanisms in the European Union on 10 October 2017 is a milestone in international tax dispute resolution. The Directive offers a…

IRS Operational Update: Reorganization and Risk-Based Approach The IRS new Large Business and International (LB&I) risk approach has been implemented in the  form of “campaigns”, focusing on weighing…