Episode 64: Transfer pricing issues raised by the digitalization of the economy — A closer look at the OECD Pillar One Blueprint

Overview

This TP Talks episode features an in-depth discussion of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options.

Featuring:

• Kartikeya Singh – Principal, PwC US Washington National Tax Services
• Giorgia Maffini – Senior Manager, Transfer Pricing and Tax Policy – PwC UK
• Stefaan De Baets – Senior Manager, Transfer Pricing – PwC Belgium

Contacts: Kartikeya Singh, Giorgia Maffini, Stefaan De Baets