TPED responds to a call for comments by the OECD
December 2020
TPED has provided comments on the OECD Public Consultation Documentation named “Reports on the Pillar One and Pillar Two Blueprints published on 12 October 2020”.
comparables Tag
TPED invited to speak by the South-African Institute of Taxation
November 2020
Three members of TPED, Sébastien Gonnet, Romero Tavares, Michael Hewson were invited to speak at the 2020 Transfer Pricing Conference of SAIT (South-African Institute of Taxation).
TPED member publishes about Safe Harbors
November 2020
Ednaldo Silva, founder of RoyaltyStat, also a member of TPED, has recently published an article about safe harbors in retail that can be applied to any industry, provided that the source data reflect the specific industry of interest.
TPED invited to deliver a masterclass
on Transfer Pricing in Dakar, Senegal
February 2020
The masterclass has been delivered in the context of the 6th Fiscal Conference of the Union des Ordres Fiscaux de l’Afrique de l’OUEST (UDOFOA/WAUTI).
TPED Research Paper receives comments
by Transfer Pricing Expert
February 2020
Transfer Pricing Expert, Oliver Treidler, publishes extensive comments on TPED’s Research Paper on MNE Tax.
TPED invited to speak
at IBFD 5th African Tax Symposium
TPED invited to speak at IBFD 5th African Tax Symposium – Trends in International Taxation: An African Perspective, in Cape Town, South- Africa.
TPED President Sébastien Gonnet presented on The Elusive Search for Comparables in Africa – a proposed process. Mr Gonnet’s presentation took place in the context of a panel covering Transfer Pricing led by Emily Muyaa.
Location Savings Adjustments to Profits
January 2019
Ednaldo Silva, Founder of RoyaltyStat, also a member of TPED, published Location Savings Adjustments to Profits in Journal of International Business and Economics (Silva, Location Savings Adjustments to Profits, JIBE, Volume 19 n°1 19 – https://www.royaltystat.com/assets/docs/RoyaltyStatLocSavAdjTP.pdf). It follows the publication of Silva, Pygmalion Comparables: Why Data from the “Center” Does Not Apply for “Periphery”, BNA Tax 23/2015, 1 (1 et seq) https://issuu.com/ednaldosilva/docs/ednaldo_silva_-_pygmalion_comparabl.
Analyzing from a Comparability Perspective,
the Mark-ups Observed in India
December 2018
TPED partners with taxsutra.com to launch a research project looking at “Analyzing from a Comparability Perspective, the Mark-ups Observed in India”.
Comparability Adjustments
A Literature Review
October 2018
Prof. Matthias Petutschnig, from WU and also a member of TPED, and Stefanie Chroustovsky from WU, publish Comparability Adjustments A Literature Review (WU International Taxation Research Paper Series No. 2018-08, 1 Oct 2018).
The Elusive Search for Comparables in Africa
TPED invited to speak at IBFD 4th African Tax Symposium – Trends in International Taxation: An African Perspective, in Mombasa, Kenya. TPED President Sébastien Gonnet presented on The Elusive Search for Comparables in Africa in a panel session covering Transfer Pricing in Africa, chaired by Emily Muyaa. The presentation aimed at evaluating the various options available to tax authorities and tax payers to cope with the lack of comparables in Africa. Aligned with the work done by the Platform of Cooperation on Tax (IMF, OECD, UN, WBG), Mr Gonnet discussed two options to establish local arm’s length ranges / safe harbors:
- Option #1 : Leverage from local domestic available financial information;
- Option #2 : Define economically-sound adjustments to non-local comparables.