An advance pricing agreement (APA) is a formal arrangement between a tax authority and a multinational enterprise (MNE) in which the parties jointly agree on the MNE's transfer pricing methodology, estimated taxable income and tax payments for a fixed period, thus reducing the likelihood of an...

A key motivation underlying the October 2020 OECD Pillar One and Pillar Two Blueprints is the goal of reducing tax complexity for taxpayers and tax authorities. In this article, we assess the tax complexity of the Blueprints relative to the 2017 OECD Transfer Pricing Guidelines (TPG) and the...

Pillar One Amount A proposes to reallocate a portion of the global profit of multinational enterprises (MNEs) from their Residence (home) and Source (host) jurisdictions to their Market (sales destination) jurisdictions. The reallocation creates a new taxing right for Market jurisdictions,...