If you ask a tax professional which topic is currently hot in international tax, the odds are high their answer is either “transfer pricing” or “BEPS”. In this short article, we discuss the relation between these two topics.
The number of transfer pricing disputes is increasing. GE, Starbucks, Apple, Facebook and Nike are just a few examples of the many MNEs that are, or have been, subject to disputes around the world. Moreover, the counter-parties of these disputes are not just tax authorities, but also supranational organizations, such as the European Union. And it is not just large-listed MNEs that face scrutiny. Smaller MNEs are subjected to the same legislation after all.
This short article first discusses the nature of transfer pricing disputes. It then lists the most common dispute areas, before moving on to a few basic measures you can take to limit your risk on a transfer pricing dispute. [Read more…]
In this article, we’ll explain the 15 action points of BEPS. We first summarize the points, and then go into more detail. We’ll also summarize what actions have been taken so far (if any).
It has been a hot topic, and after hearing it a few times you might wonder: What is BEPS? In this article, we explain the different meanings given to the word in practice and the way this came to be. [Read more…]