The project aims at conducting rigorous research concerning the use of transfer pricing “safe harbors”, and to test the potential practical and conceptual limits of such instruments considering the arm’s length principle.
TPED General Assembly (members only), 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. 2019 activities and financials of the Association were presented, as well...
TPED is pleased to announce the publication of a Research Paper covering an economically sound and beneficial framework for selecting and adjusting foreign comparables, especially relevant in emerging and developing countries lacking comparables.
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”.
We believe that a French version of tped.eu will be particularly useful notably in French-speaking African countries who are increasingly endorsing transfer pricing regulations. As a reminder, the following African French Speaking Countries do have a Transfer Pricing Legislation: Benin, Burkina Faso, Cameroon, Central Africa...