TPED Research on Comparability Adjustments project aims at identifying solutions to cope with the lack of comparables in emerging economies and developing countries.
TPED members Bert Steen, Sébastien Gonnet, Christof Beuselinck, Matthias Petutschnig and Thibaut Roques (not a TPED member) published “Transfer Pricing Comparables: Preferring a Close Neighbor Over a Far-Away Peer?” in the Journal of International Accounting, Auditing & Taxation.
We are happy to announce that our paper entitled “Transfer Pricing Comparables: Preferring a Close Neighbor over a Far-Away Peer?” has been accepted for publication in the Journal of International Accounting, Auditing and Taxation (forthcoming 2022)....
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”.
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.
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.
Transfer Pricing Expert, Oliver Treidler, publishes extensive comments on TPED’s Research Paper on MNE Tax.
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”.
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.