The Israel Tax Authority is questioning whether costs plus markup models Israeli R&D affiliates are at arm's length. This could present issues for multinationals that have not been giving proper consideration to cost base, asset intensity and ownership of valuable intangibles in their benchmarking.

Topics: Intangibles DEMPE Benchmarking Base Erosion and Profit Shifting (BEPS) Tax Policy

Following its neighbor Australia, New Zealand has issued a large assessment to Oracle related to its distribution affiliate. We explore potential comparability and BEPS issues that could play a role in the dispute.

Topics: Base Erosion and Profit Shifting (BEPS) TNMM/CPM Profit Indicators Comparability

Changes to tax laws are often seen as the primary solution to curb profit shifting. However, proper application of the arm's length principle alongside BEPS CbCR disclosures already offer powerful tools in this endeavor.

Topics: Base Erosion and Profit Shifting (BEPS) Tax Policy TNMM/CPM Pharmaceutical Industry