This article was first published on International Tax Review and is reproduced on this blog with the authorization of its authors. Julien Pellefigue of Deloitte Société d’Avocats explains the importance
Employment protection plan and transfer pricing policy, careful to the mix of genres
If the introduction of an employment protection plan can be a complicated procedure in employment law given the legal framework that this procedure benefits from, it should moreover be noted
Going further than the comparability adjustments typically made in economic analyses
The practical application of several transfer pricing methods involves comparing the profit of an enterprise (or one of its activities) with the profit of independent enterprises considered as “comparable”. The
Profit split: uncertainty remains
As part of the BEPS project, the OECD is updating its applicable transfer pricing guidelines. One of the most controversial issues in this update is the use of profit split.
CbCR: OECD clarifications on its implementation
Following on from the BEPS and in particular Action 13 reports, the OECD has recently published three important documents aiming at providing greater legal certainty for tax administrations and multinational
Amazon: IRS loose again
In the March 23rd, 2017 decision Amazon.com, Inc. v. Commissioner, T.C., No. 31197-12, 148 T.C. No. 8, the US Tax Court concluded that the United States tax authorities had an
The Future of Transfer Pricing – Focus on France
This article was first published in Les Cahiers de l’IFA, volume 102, The future of transfer pricing, July 2017 Download the original version of this article This article
How to get through the fiscal Middle Ages in Europe ?
For a millennium, Europe experienced a chaotic transition from the Roman Empire order to the one of nation states that emerged during the Renaissance. During this period of time, the