Publications Archives

TPED publications cover primarily the economics of transfer pricing relevant to emerging and developing countries, and range from responses to calls for comments by international institutions to publications in transfer pricing or academic journals.

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”.

OECD, comparables, digital

TPED member publishes about Safe Harbors

by TPED

Research Areas, Safe Harbors, Publications

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.

comparables, safe harbors, usa

Proposed Framework for Foreign Comparables
Selection and Adjustment

by TPED

Research Areas, Coping with the lack of comparables, Publications

December 2019

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.

Sébastien, Matthias, Bert, Christof

TPED responds to call for comments by the OECD

by TPED

Research Areas, Coping with the lack of comparables, Publications

November 2019

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”.

Sébastien, Matthias, Bert, Christof

Location Savings Adjustments to Profits

by TPED

Research Areas, Coping with the lack of comparables, Publications

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.

Ednaldo, comparability, adjustments, comparables

Comparability Adjustments
A Literature Review

by TPED

Research Areas, Coping with the lack of comparables, Publications

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).

Matthias, comparability, adjustments, comparables

The Hidden Cost of Tax Incentives in Mining

by TPED

Publications

July 2018

TPED issued comments after the release by IGF/OECD of the Draft on the Hidden Cost of Tax Incentives in Mining (https://www.oecd.org/tax/beps/hidden-cost-of-tax-incentives-in-mining-draft-toolkit-oecd-igf.pdf).

OECD, Sébastien, Giammarco, Laurence, mining, tax

Economic Aspects of the Taxation of Offshore Indirect Transfers

by TPED

Publications

October 2017

TPED issued comments after the release by The Platform For Collaboration on Tax of the Draft on the Taxation of Offshore Indirect Transfers.

The Platform for Collaboration on Tax is a joint effort launched in April 2016 by the International Monetary Fund (IMF), the Organisation for Economic Co-operation and Development (OECD), the United Nations (UN) and the World Bank Group (WBG). The Platform is designed to intensify the co-operation between these International Organisations (IOs) on tax issues.

Sébastien, Romero, OIT, offshore, immovable, Giammarco, Pim