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default OECD Proposals Undermine The Arm’s Length Principle

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OECD Proposals Undermine The Arm’s Length Principle

The Organisation for Economic Cooperation and Development (OECD) recently released a policy note (approved by the 127 members of its Inclusive Framework (IF)), hosted a webcast and held a public consultation meeting to consider possible solutions to the tax challenges arising from digitalization of the economy.

pdf How Technology Is Changing Taxation In Latin America

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180921 Tax Authorities Are Powering Processes With Artificial Intelligence (AI).pdf

How Technology Is Changing Taxation In Latin America

This article provides an overview of the important role played by technology in taxation and transfer pricing in Latin America, and presents comprehensive research to illustrate the digital path taken by tax administrations and corporations in Latin America and worldwide.

default Spotify White Paper - Summary

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Spotify White Paper - Summary

Spotify White Paper - Summary Over the last couple of years it has become increasingly apparent that the big tech players are difficult to value, due to a variety of reasons. The main reason is that there seems to be different valuation-metrics in the tech market than in other markets. A shift is recognized where a Return on Data (RoD) is replacing the more traditional Return on Investment (RoI).

pdf Multinational Enterprises, Transfer Pricing and Value Chain Analysis in Latin America following the OECD/G20 Base Erosion and Profit Shifting Initiative

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181016 TPA Global MNEs TP and VCA in LATAM 1.pdf

Multinational Enterprises, Transfer Pricing and Value Chain Analysis in Latin America following the OECD/G20 Base Erosion and Profit Shifting Initiative

This article examines the holistic transfer pricing approach that a number of Latin American countries have been implementing into their laws following the OECD/G20 Base Erosion and Profit Shifting (BEPS) initiative. In this context, a value chain analysis (VCA) approach aligns business models, finance and/or tax positions and the governance of multinational enterprises (MNEs) with best practice under the OECD/G20 BEPS initiative.

pdf BEPS - Interest Deductibility Rules Popular

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Article_Interest deductibility rules.pdf

BEPS - Interest Deductibility Rules

This article addresses BEPS Action 4. The author(s) provide a historical perspective of the relevant BEPS and EU measures, explain the highlights of BEPS Action 4, discuss the overlap between the different Actions, update readers on country-specific implementation of BEPS Action 4, summarize existing case law in the area, present practical examples dealing with the impact of Action 4 on certain structures and, finally, provide concluding remarks.

pdf TTI's ERP2Tax Solution Achieves Certified Integration with SAP Applications Popular

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180612 TTI's ERP2Tax Solution Achieves Certified Integration with SAP Applications.pdf

TPA Global serves as a one-stop-shop for automating your TP workflows and is ready to assist you in TP software diagnostic, design and implementation stages. With ITT’s certified integration with the SAP ® ERP application, TPA Global confirms its services with ERP2Tax, assisting corporations in expanding the use of data from SAP ERP to support complex tax calculations that are part of the 2017 Tax Reform, such as Section 965 toll charge, GILTI, BEAT, FDII and Section 163(j). 

pdf Profit Allocation in the Pharma Industry - Who Wants a Slice of the Tax Pie Popular

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180327 Profit Allocation in the Pharma Industry.pdf

Profit Allocation in the Pharma Industry - Who Wants a Slice of the Tax Pie

As many countries are now fully armed to combat corporate tax avoidance, tax authorities have started insistently claiming their ‘‘fair share’’ of tax income. They all are looking at the same profit, yet aiming to get a bigger piece, if not the whole ‘pie’. Facing this perfect tax storm, multinational enterprises should be proactive in determining how the profit is allocated.

pdf How to Align the Value Creation Factors on the Rubik’s Cube Techniques to Excel in Value Chain Analysis Popular

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180207 How to Align the Value Creation Factors on the Rubik’s Cube - Techniques to Excel in VCA.pdf

How to Align the Value Creation Factors on the Rubik’s Cube   Techniques to Excel in Value Chain Analysis

China has made significant contributions in driving forward the roll-out of the G20/OECD BEPS actions. In the last two years, with the release of Bulletin 42 on transfer pricing documentation, Bulletin 64 on advance pricing arrangements, and Bulletin 6 on further developing its transfer pricing regime by the State Administration of Taxation (SAT), China has entered into a new era for combating base erosion and profit shifting through transfer pricing. Value chain analysis (VCA) has become a focal point with respect to transfer pricing compliance for many multinational enterprises in China.

default CFO’s Roadmap - Step 1: Robust synchronization of financial data analytics Popular

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The first step to being fully in control is obtaining control over your financials and ensuring that they are fully aligned with your operational conduct. This is absolutely essential in the current tax arena as availability of information via CbC reporting and automatic exchange of such information mandates companies to be extremely careful in their selection of reported data.

pdf Bridging the CCCTB and the Arm’s Length Principle – A Value Chain Analysis Approach Popular

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171108 Bridging the CCCTB and the Arm’s Length Principle SH LV JM.pdf

Bridging the CCCTB and the Arm’s Length Principle – A Value Chain Analysis Approach

Formulary apportionment models of taxation have oftenbeen proposed as a means to resolve current tax planning leakages and conflicting positions regarding the interpretation of tax treaties. The emblematic example of formulary apportionment, often referred to as “unitary taxation”, practised amongst jurisdictions such as the United States and Canada, has provided the inspiration for the creation of a peculiar EU variety of formulary apportionment.

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  • 20 June 2019
  • Guest user downloaded the DOCman document with the title TPA representations highlights, Chapter VI OECD Guidelines
  • Guest user downloaded the DOCman document with the title ‘Status implementation article 7 Authorized OECD Approach (AOA) into local tax law and double tax treaties’
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  • Guest user downloaded the DOCman document with the title Unilateral BEPS Initiatives: The Emperor’s New Clothes OR How Countries Go To War?
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