A common question is, “when does transfer pricing occur.” It occurs typically when multi-national companies enter into sale and purchase transactions with their related companies, or loan to related companies. It can be also a situation, when a Singapore parent...
Comprehensive anecdotal and academic evidence reveals that multinational enterprises (MNEs) transfer income from high-tax countries to low-tax jurisdictions to reduce their corporate tax burden. Political and public debates on the topic were recently reignited by the...
Dealing with base erosion and profit shifting presupposes that it is known what this is. The concept of value creation claims to provide an answer as to where profits should be taxed and, therefore, when the tax base is being shifted. The OECD introduced value...
All multinational groups (MNEs) are, should or will be addressing their existing international tax planning structures with respect to a new world that is rapidly changing in apparently dramatic ways. The process may be supervised at the level of the board of...
The intention here is to assess the (highly practical) matter of whether the OECD’s Base Erosion and Profit Shifting (BEPS) project has helped, or alternatively hindered, the task for developing countries of applying transfer pricing rules pursuant to the arm’s length...
Part I of this three-part series addressed one of the considerations that MNEs may want to take into account when adapting their effective tax rate strategies (ETR strategies) in the evolving world of global tax planning.1 The current global tax environment,...
