Slicing the Pie - A Quantitative Value Chain Analysis
Following BEPS publication on profit split on October 5, 2015 and July 4, 2016, MNEs are being challenged to apply the holistic view on...
Nov 16, 2016
Top Transfer Pricing Challenges for the Agricommodities Industry
By Katerina Miari and Steef Huibregtse. The complexities of transfer pricing, particularly in the midst of BEPS-driven reforms, have...
Oct 31, 2016
China Takes the Lead on Transfer Pricing Policy: Combating BEPS Through a Value Chain Analysis
By Steef Huibregtse and Ying Van Galen Wang. The authors cite support for a ‘‘value chain analysis’’ in OECD draft and final BEPS...
Oct 27, 2016
Corporate ‘Tax’ Governance: A Necessary Addition to Best Practices for Businesses?
By Steef Huibregtse and Avisha Sood. Management of an entity’s tax strategy has historically been down to finance directors and has...
Jul 16, 2016
How to Make Intercompany Loans BEPS Proof
By Steef Huibregtse, Virender Sharma and Maria Grigoryeva. Debt as intercompany financing with excessive interest deductions has come...
Apr 16, 2016
The Perfect Tax Storm! Full Disclosure of all Topics to all Stakeholders in Real Time
By Steef Huibregtse, Maria Grigoryeva and Margie van der Valk. On October 5, 2015 recommendations on disclosing tax arrangements were...
Mar 16, 2016
A Post-BEPS Primer for CFOs: Is the In-House Transfer PricingTeam in Control?
By Steef Huibregtse and Igne Valutyte. The authors set forth a practical approach for chief financial officers seeking to ensure the...
Dec 15, 2015
Unilateral BEPS Initiatives: The Emperor’s New Clothes OR How Countries Go To War?
Steef Huibregtse, Avisha Sood, Margie van der Valk and Igne Valutyte. The authors are lawyers at TPA Global. Progress has been...
Nov 6, 2015
Status of Implementation of the Authorized OECD Approach into Domestic Tax Law and Tax Treaties
Part 2. By: Steef Huibregtse, Louan Verdoner, Igne Valutyte and René Offermanns. This article examines profit/loss allocation in a...
Sep 1, 2015
Status of Implementation of the Authorized OECD Approach into Domestic Tax Law and Tax Treaties
Part 1. By: Steef Huibregtse, Louan Verdoner, Igne Valutyte and René Offermanns. This article examines profit/loss allocation in a...
Aug 1, 2015
A Post-BEPS Primer for Boards: Staying in Control of Transfer Pricing Risks
By Steef Huibregtse and Igne Valutyte. The authors outline areas of inquiry for board members seeking to ensure that company tax...
Jul 1, 2015
Transfer Pricing for Funds: Dealing with ‘People Functions’ and Challenges from Tax Authorities
By: Steef Huibregtse, Casrsten Schmid, Margie van der Valk and Avisha Sood. Aligning substance with value creation and the extent to...
Mar 9, 2015
Transfer Pricing in Mining: an African Perspective
A briefing note. By: Pietro Guj, Bryan Maybee, Frederick Cawood, Boubacar Bocoum, Joel Cooper, Nishana Gosai and Steef Huibregtse....
Sep 1, 2014
Managing Controversy after BEPS
This article delves into the intricate relationship between Base Erosion and Profit Shifting (BEPS) and the escalating risk of tax...
Jul 17, 2014
Interim Information Report on Transfer Pricing in Mining An African Perspective
By Pietro Guj (Corresponding author), Bryan Maybee, Frederick Cawood, Joel Cooper, Nishana Gosai and Steef Huibregtse. Possible ongoing...
Jul 17, 2014
How to deal with the new generation of intangibles
By: Steven Carey, Steef Huibregtse and Vishnu Bagri. The new generation of intangibles come in many shapes and forms. Almost all are...
Dec 31, 2012
IP companies and substance: no-fly zones?
By: Steef Huibregtse, Mark Peeters, Louan Verdoner and Steven Carey. Intellectual Property (“IP”) generally represents between 40 percent...
May 20, 2011
A Cross-Country Perspective on Beneficial Ownership – Part 2
By: Louan Verdoner, René Offermanns and Steef Huibregtse. In this two-part article, the authors examine the beneficial ownership concept...
Oct 1, 2010
A Cross-Country Perspective on Beneficial Ownership – Part 1
By: Louan Verdoner, René Offermanns and Steef Huibregtse. In this two-part article, the authors examine the beneficial ownership concept...
Aug 24, 2010
Pan-European APAs – a regional approach to transfer pricing risk management
By: Louan Verdoner and Steef Huibregtse. In recent years multinational enterprises have concluded Advance Pricing Agreements with tax...
Jan 1, 2010