comparables Tag

TPED / Posts tagged "comparables"

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.

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.

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.