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).

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.

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.

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). 

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.