Amount B
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If you are out of Amount B, you can let go a sigh of relief
Originally published: March 2024 A transfer pricing (TP) specialist recently told me: “if you do the analysis and conclude you’re not in scope of Amount B, you can let go a sigh of relief”. Many saw the potential for TP simplification in Amount B as promising. But the mood has shifted, especially after last month’s… Continue reading
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Poetic Justice
Originally published: January 2023 The OECD system of transfer pricing (TP) aims to achieve complete justice through economics. This means that countries get allocated taxing rights on only those profits economically ‘arise’ through operations in its country. In theory, this means ‘profit shifting’ can only occur through shifting of economic activity, ie there is no… Continue reading
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Solta O Frango
Originally published: January 2023 Brazil is going through political turmoil, as rioters stormed key government buildings this week, which is not good for anyone. Like everyone else, I hope that Brazil finds a way to mend its tensions. Lots of these tensions have been on display in the past years. On the tax side, Brazil… Continue reading
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ABC
Originally published: January 2023 For decades, some developing countries have had two main complaints about international tax: (1) transfer pricing (TP) is too complex and could really use some standardized numerical rules (eg https://lnkd.in/ea2XPpru) and (2) not enough profits get allocated to source and/or market jurisdictions. These complaints were consistently dismissed, until certain European countries started… Continue reading
About Me
I am Leonard, an experienced M&A Tax and International Tax expert. I write about tax on LinkedIn and Twitter sometimes (but mostly LinkedIn). People liked the posts, but there were too many of them to keep track of. So, now they are on a blog for future reference.
Obvious disclaimers on all my posts: this is not advice. These views are my own and do not necessarily represent my employer.
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