Author: TPED

TPED / Articles posted by TPED

TPED President Sébastien Gonnet presented on the subject of the lack of comparables in Africa. He presented a proposed process for selecting foreign comparables in the absence of domestic comparables. Within this process, the country risk is a key comparability factor and the proposition involves selecting comparables from countries with similar risk profiles (and cost of doing business), proxied by the country rating. The conference was also the occasion to announce the publication in December 2019 of a Paper on the subject. The Paper is a response to the call for Research on comparables by the Platform of Cooperation on Tax (IMF, OECD, UN, WBG).

The tax challenges of the digitalisation of the economy were identified as one of the main areas of focus of the Base Erosion and Profit Shifting (BEPS) Action Plan.

In light of the high stakes and the need for a clear direction, the OECD Secretariat has developed a “Unified Approach” which is outlined in the document named “Secretariat Proposal for a Unified Approach under Pillar One”.

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.

TPED General Assembly (members only), took place in Vienna (in advance of the Global Transfer Pricing Conference organized by the Institute on Tax’s Transfer Pricing Center of WU - Vienna University of Economics and Business). 2018 activities and financials of the NGO were presented, as...

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.