Research Areas, Publications and News

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.

TPED and WU (Vienna University of Economics and Business) Associate Professor Matthias Petutschnig launch the “Comparability Research Project (2018-2019)”. The project aims at identifying solutions to cope with the lack of comparables in emerging economies and developing countries.

The absence of domestic comparables has been pointed out by the Platform for Cooperation on Tax (IMF, OECD, UN, WBG ) as one of the major obstacle to apply the arm’s length principle in emerging economies and developing countries. In its Toolkit for Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses, the multilateral bodies call for additional economic research, notably in the field of comparability adjustments.

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.