This article describes various methods of monetizing different types of user-generated data within digital business models and concludes that the user participation is higher in income generation through advertising as opposed to through pay-as-you-go fees. The differentiation of advertising income is also supported by an analysis of the beneficiaries of network effects, by a survey of the financial statements of the biggest digital service companies and by practical examples that challenge arguments brought forward by the OECD and European Union for taxing digital business profits in market jurisdictions.
{"title":"Deconstructing User Participation: Why in the Digital Era Advertising Income Is Different from Other Business Income","authors":"E. Vėgėlytė","doi":"10.59403/1ze7vbw","DOIUrl":"https://doi.org/10.59403/1ze7vbw","url":null,"abstract":"This article describes various methods of monetizing different types of user-generated data within digital business models and concludes that the user participation is higher in income generation through advertising as opposed to through pay-as-you-go fees. The differentiation of advertising income is also supported by an analysis of the beneficiaries of network effects, by a survey of the financial statements of the biggest digital service companies and by practical examples that challenge arguments brought forward by the OECD and European Union for taxing digital business profits in market jurisdictions.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":"6 3","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-05-13","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141205031","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article analyses whether limited-risk entities may bear under arm’s length conditions a portion of the negative financial consequences deriving from the current COVID-19 disruption. Furthermore, the article offers an overview of the impacts of the COVID-19 emergency on the benchmark analyses for 2020, on transfer pricing documentation and on unilateral and bilateral advance pricing agreement (APA) procedures.
{"title":"The Impact of COVID-19 on Transfer Pricing: Issues Arising during the Economic Downturn and Possible Solutions","authors":"M. Cataldi, A. Alfano","doi":"10.59403/p9nyjt","DOIUrl":"https://doi.org/10.59403/p9nyjt","url":null,"abstract":"This article analyses whether limited-risk entities may bear under arm’s length conditions a portion of the negative financial consequences deriving from the current COVID-19 disruption. Furthermore, the article offers an overview of the impacts of the COVID-19 emergency on the benchmark analyses for 2020, on transfer pricing documentation and on unilateral and bilateral advance pricing agreement (APA) procedures.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":"50 3","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-04-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141209309","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article briefly reviews the tax resolution procedures available within Spanish legislation, analysing how the transposition of Council Directive 2017/1852 will affect tax dispute resolution procedures in Spain.
{"title":"The Transposition of the EU Directive on Tax Dispute Resolution Mechanisms in Spain","authors":"F. Carreño, L. Millán","doi":"10.59403/2rhm4bc","DOIUrl":"https://doi.org/10.59403/2rhm4bc","url":null,"abstract":"This article briefly reviews the tax resolution procedures available within Spanish legislation, analysing how the transposition of Council Directive 2017/1852 will affect tax dispute resolution procedures in Spain.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":"15 11","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-04-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141211748","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article provides an overview of the current status quo of the digital services tax proposal in the Czech Republic and also describes the key features of the proposed tax.
本文概述了捷克共和国数字服务税提案的现状，并介绍了拟议税收的主要特点。
{"title":"Introducing a Digital Services Tax in the Czech Republic","authors":"X. Yeroshenko","doi":"10.59403/11n5at6","DOIUrl":"https://doi.org/10.59403/11n5at6","url":null,"abstract":"This article provides an overview of the current status quo of the digital services tax proposal in the Czech Republic and also describes the key features of the proposed tax.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":"78 21","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-04-14","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141214087","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
With the recent implementation of BEPS Action 8 and the revised chapter VI of the 2017 OECD Guidelines, a number of questions has arisen around transactions involving the use of intangible assets and especially around the substance required to claim their ownership – the so called DEMPE functions. The purpose of this article is to understand the practical application of the DEMPE concept to pharmaceutical companies active in the development, manufacturing and distribution of generic drugs.
{"title":"Application of the DEMPE Concept in the Pharmaceutical Industry","authors":"G. Vallat","doi":"10.59403/16db3zy","DOIUrl":"https://doi.org/10.59403/16db3zy","url":null,"abstract":"With the recent implementation of BEPS Action 8 and the revised chapter VI of the 2017 OECD Guidelines, a number of questions has arisen around transactions involving the use of intangible assets and especially around the substance required to claim their ownership – the so called DEMPE functions. The purpose of this article is to understand the practical application of the DEMPE concept to pharmaceutical companies active in the development, manufacturing and distribution of generic drugs.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":"67 9","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-04-09","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141215784","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article summarizes the information to be documented in the Master File and Local File, the guidance by the Commissioner of the IRD, the exemption criteria from the need to prepare Master File/Local File documentation, and the implications for exempt taxpayers.
{"title":"Hong Kong Documentation Requirements: Regulations, Exemptions and Supporting Your Transfer Pricing","authors":"A. Tse, M. Dmello","doi":"10.59403/3e2fand","DOIUrl":"https://doi.org/10.59403/3e2fand","url":null,"abstract":"This article summarizes the information to be documented in the Master File and Local File, the guidance by the Commissioner of the IRD, the exemption criteria from the need to prepare Master File/Local File documentation, and the implications for exempt taxpayers.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":"24 4","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-04-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141215889","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article provides an overview of the development of chapter VI of the OECD Guidelines with respect to the specific addition of hard-to-value intangible (HTVI) as a new concept in the OECD’s transfer pricing guidance. Furthermore, it presents an approach to taking uncertainty into account when valuing HTVIs at best knowledge at the time such a transaction is entered into.
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations are of the utmost importance in the sphere of transfer pricing. Unlike article 9 of the OECD Model, which is rather general in wording, the OECD Transfer Pricing Guidelines offer a detailed guidance on transfer pricing methodology. The significance of the OECD Transfer Pricing Guidelines became even more noticeable when the BEPS Project was completed, because numerous changes to the global transfer pricing regime were envisaged in the amended guidelines and not in the text of the OECD Model itself. The aim of this article is to analyse the status of the OECD Transfer Pricing Guidelines in international and Polish domestic law, as well as current practice of their application.
{"title":"OECD Transfer Pricing Guidelines as a Quasi Source of Law in a Post-BEPS World – Legislative and Judicial Developments from a Polish Perspective","authors":"B. Brzeziński, K. Lasiński-Sulecki, W. Morawski","doi":"10.59403/8p0kjq","DOIUrl":"https://doi.org/10.59403/8p0kjq","url":null,"abstract":"The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations are of the utmost importance in the sphere of transfer pricing. Unlike article 9 of the OECD Model, which is rather general in wording, the OECD Transfer Pricing Guidelines offer a detailed guidance on transfer pricing methodology. The significance of the OECD Transfer Pricing Guidelines became even more noticeable when the BEPS Project was completed, because numerous changes to the global transfer pricing regime were envisaged in the amended guidelines and not in the text of the OECD Model itself. The aim of this article is to analyse the status of the OECD Transfer Pricing Guidelines in international and Polish domestic law, as well as current practice of their application.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":" 27","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-03-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141220782","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The OECD’s efforts towards addressing the tax challenges arising from digitalization recently reached a new significant phase of work. Indeed, the three-tier profit allocation mechanism embedded in the Secretariat Proposal for a “Unified Approach” under Pillar One (published in October 2019) represents a remarkable and potentially disruptive step forward in the discussion surrounding the taxation of the digital economy. The aim of this article is to contribute to such discussion by analysing the three-tier profit allocation mechanism, evaluating its potential impacts and highlighting its strengths and weaknesses.
{"title":"The OECD Secretariat Proposal for a “Unified Approach” under Pillar One: Strengths and Weaknesses of the New and Revised Nexus and Profit Allocation Rules","authors":"Adv. LL.M, A. Samari","doi":"10.59403/3yggys5","DOIUrl":"https://doi.org/10.59403/3yggys5","url":null,"abstract":"The OECD’s efforts towards addressing the tax challenges arising from digitalization recently reached a new significant phase of work. Indeed, the three-tier profit allocation mechanism embedded in the Secretariat Proposal for a “Unified Approach” under Pillar One (published in October 2019) represents a remarkable and potentially disruptive step forward in the discussion surrounding the taxation of the digital economy. The aim of this article is to contribute to such discussion by analysing the three-tier profit allocation mechanism, evaluating its potential impacts and highlighting its strengths and weaknesses.","PeriodicalId":517680,"journal":{"name":"International Transfer Pricing Journal","volume":" 46","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-03-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141223127","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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