Research Areas, Publications and News

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.

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.