October 5, 2022
The widespread implementation of the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules is now a strong probability This episode of KPMG Inside International Tax discusses the many pitfalls that these rules may present to taxpayers currently engaging in M&A transactions.
September 26, 2022
In a series of three articles, which appeared in Tax Notes International, the authors assess the merits of the arm's-length principle and the significant problems with global formulary apportionment—the perceived alternative. They also consider the impact that the BEPS 2.0 project and other OECD initiatives may have on the future of transfer pricing.
August 25, 2022
The impacts of Pillar One and Pillar Two on transfer pricing vary by jurisdiction, taxpayer, and the likelihood of ultimate adoption. This KPMG Exploring Transfer Pricing podcast provides a high-level overview of the two pillars, a starting point for understanding the possible implications for transfer pricing.
July 11, 2022
This article, which appeared in Tax Notes International, examines a significant but frequently overlooked piece of the OECD’s Pillar 1 proposal, Amount B. The KPMG authors explain how Amount B could work, discuss implementation challenges, and consider how businesses can prepare.
July 4, 2022
In this article, which appeared in Tax Notes International, the KPMG authors examine the status of the OECD’s two-pillar approach to modernizing the international tax system and consider the international implications of the different paths countries are taking to implement Pillars 1 and 2.
June 22, 2022
This KPMG Inside International Tax podcast episode examines the current status of Pillar Two implementation and the potential complexities that U.S. multinationals may have to navigate as the current U.S. tax rules interact with any future Pillar Two legislations implemented by our trading partners.
June 2022
Consumer and retail companies are revisiting their e-commerce and direct-to-consumer methodologies with large-scale digital transformations and targeted customer centric considerations. All consumer and retail companies investing in e-commerce should revisit their operating models and structures to help ensure they are properly addressing the relevant tax implications and potentially unlocking tax value.
May 13, 2022
Learn more about the differences between OECD Local Files—guidance introduced as an output from the BEPS action plan—and other types of Local documentation requirements in this KPMG Exploring Transfer Pricing podcast.
May 2022
The latest issue of KPMG Chief Tax Officer Insights explores how CTOs are approaching scenario planning for potential Pillar Two rules.
April 18, 2022
This KPMG Exploring Transfer Pricing discusses the importance of a well-prepared Master File, the “bass line” for global transfer pricing documentation, for which the OECD prepared guidelines as an output from the BEPS action plan.
More recent articles, podcasts, and more
Archive (2016-2021)
2021
2020
October 12, 2020 | KPMG Report: Summary and Initial Analysis of Pillar One Blueprint
October 12, 2020 | KPMG Report: Summary and Initial Analysis of Pillar Two Blueprint
August 31, 2020 | The State of Country-by-County Reporting | Tax Notes International
August 26, 2020 | It's Complicated — It's Really Complicated (DAC6) | Thomson Reuters Tax & Tech Talks podcast
July 31, 2020 | INSIGHT: Transfer Pricing Substance in Flux — DEMPE, BEPS 2.0, and COVID-19 | Bloomberg Tax
February 13, 2020 | KPMG Report: Insights on OECD's Revised "Unified Approach" to Tax Challenges of Digitalisation
February 13, 2020 | KPMG Report: OECD Transfer Pricing (Final) Guidance on Financial Transactions: Initial Impressions
January 2020 | Managing the Uncertainty of Digital Taxation | KPMG CTO Insights — Spotlight Edition
2019
December 2019 | OECD's Unified Proposal on Pillar One Poses Challenges for Dispute Resolution | International Tax Review
November 11, 2019 | BEPS 2.0 Unpacked: What you should know about the OECD's current effort to modify the global taxing rules for multinational companies | KPMG video
November 2019 | Global Glare: International Tax Reform Steals the Spotight | KPMG CTO Insights
October 21, 2019 | INSIGHT: Taxing the Digital Economy – As Simple as "A, B, C"? | Daily Tax Report
October 9, 2019 | KPMG Report: CFC Rules under ATAD – Overview and Implementation Status
September 2019 | Digital Taxation: International Focus, Individual Doubt | KPMG CTO Insights – Issue Spotlight
August 13, 2019 | INSIGHT: Cost-Plus Transfer Pricing for Marketing Support Services between BEPS 1.0 and BEPS 2.0 | Daily Tax Report
August 8, 2019 | KPMG Report: Corporate Tax Transparency in the BEPS Era – Tax Departments in the Spotlght
July 3, 2019 | KPMG Report: BEPS for Asset Management – Changing International Tax Landscape
June 13, 2019 | KPMG Report: BEPS Action 8–10 – Current State of Play
May 11, 2019 | KPMG Report: Taxation of the Digitial Economy – 2019 to Be a Pivotal Year
May 6, 2019 | The U.S. Proposed Digital Services Tax | KPMG In Dispute podcast
May 2019 | Potential Impact of the Taxation of the Digital Economy | KPMG Video
May 2019 | BEPS, DEMPE & Defending Your Value Chain | KPMG Video
April 19, 2019 | OECD's Proposals on Taxing the Digital Economy: A look at the OECD's proposals and how they compare to prior efforts
February 2019 | CTOs and the Taxatio of the Digital Economy | KPMG CTO Insights
2018
July 12, 2028 | OECD Super Treay Enters into Force July 1: A Primer | Tax Management Transfer Pricing Report
May 2018 | The BEAT and Bilateral Tax Treaties: Where Might the Tension Lead | ABA Tax Times
February 16, 2018 | BEAT's Impact on Transfer Pricing Alternative Dispute Resolution | Daily Tax Report
February 2018 | Across the Line: Navigating Global Tax Challenges | KPMG CTO Insigths
2018 | KPMG Report: Post-BEPS Tax Controversy—Preparing for New Rules, New Risks
2017
August 11, 2017 | Understanding the Operation, Impact, and Practical Implications of the MLI | Tax Management International Journal
August 7, 2017 | Because Not There, Neither Here? Examining the 'Mirror Legislation' Status of the U.K.'s New Anti-Hybrid Rules | Tax Notes International
2017 | OECD Master File Considerations: North America | Expert Guides, Transfer Pricing Advisers
June 1, 2017 | Ten Questions on the OECD's DEMPE Concept and Its Role in Valuing Intangibles | Tax Management Transfer Pricing Report
May 26, 2017 | Planning for the Future State of Income Tax Treaties: A Primer on the OECD's Multilateral Instrument | KPMG What's New in Tax
March 2017 | Treaty Benefits for Investment Vehicles in a Post-BEPS World | Taxes, The Tax Magazine
2017 | KPMG Report: Enhancing Value in a Disruptive Environment
2017 | KPMG Report: The BEPS Ripple Effect, Multinationals Are Reevaluating How and Where They Do Business
2016
September-October 2016 | Country-by-Country Reporting: Identifying the Elephant | International Tax Journal
July 26, 2016 | Country-by-Country Reporting: Are We There Yet?, | Daily Tax Report
July 14, 2016 | Transfer Pricing for Financial Transactions: Determining Credit Ratings | Tax Management Transfer Pricing Report
May 18, 2016 | KPMG Report: 2x4 Approach to Country-by-Country Reporting
May 2, 2016 | The Post-BEPS World of Permanent Establishment | Tax Notes International
April 14, 2016 | Country by Country, Step by Step: Implementation Considerations for Country-by-Country Reporting by U.S. Multinationals | Tax Management Transfer Pricing Report
January-February 2016 | Are You Considering an Advance Pricing Agreement? Companies Need to Conduct Benefit Analysis to Determine if APA Is Best Approach | Tax Executive
January 1, 2016 | Country-by-Country Reporting: New Year, New Rules? | Daily Tax Report
