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Thanks for the good simple example.

Thank you for this

What are the pros and cons of implementing it?

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مرحبا استاذ ان شاءالله تكون بخير. عندي سؤال و اتمنى تساعدني او تنصحني، انا خلصت بكلوريوس ادارة اعمال عالميه بهولندا جامعة تلبورخ، و حاليا حابه اكمل ماستر بس محتاره. في ماستر اسمه international business taxation. وانا حابه هالمجال ولكن خايفه انه مايكون اله مستقبل او شغل. فعندك نصايح؟ او فكره عن الموضوع؟ اتمنى تساعدني. طبعا في ماستر ماليه و في محاسبه وفي استشارات وكتير خيارات تانيه بس انا محتاره والتسجيل باقي له كم يوم.

great video! could you please make one about the 2024 appeal, where pepsico won? thank you :)

Are you based in London? I'm interested in attending the course

Thanks for this detailed explanation. This helps a lot!

An issue with the matrix - if OA/Sales > 15% then OE/Sales does not matter. Which is weird if one thinks higher functions should be compensated with a higher margin.

Neither expert provided useful evidence but this issue could have been properly addressed as I noted in "Royalty Rate in PepsiCo v. Commissioner: The Right Answer for the Wrong Reasons", Tax Notes International, January 22, 2024. CUT approaches were not used in the Coca Cola v. IRS case which has similarities to this issue. Something less aggressive than the IRS profits based approach would have led to a conclusion similar to what the Judge ended up with.

This 25% rule was devastated in Microsoft v. Uniloc and it has always been junk science. But to repeat my earlier comment - this issue was never the profits of the bottler but the profits of Pepsi in producing and selling syrup. Ms. Wright addressed the wrong question throughout as the judge noted.

Dana Wright did not understand the issue. So your paragraph 296. The issue was not the intangible profits received by the bottler which of course are near zero. The issue was how much of the third party payment represents the IP value received by Pepsi as producer/seller of syrup. Your discussion unfortunately goes down the rabbit hole Wright followed.

"You can literally smell the bias of the judge here" hahah. Pretty interesting ruling indeed...

Incredible. Thank you

Great video!

By the way I think the supreme court had no other option just turn to the international private law to determine the owner as the same would need to happen eg in the case there is a criminal investigation about a financial fraud concerning stolen investments/ stocks of investors...

Amazing seeing that the supreme court did not take the right to "correct" a legislative "error" (i.e., adding the missing e.g., expression in the second sentence) and did not overstep its function in the legislative/judiciary system. (Although I do not know the exact legislative Dutch wording style and I cannot judge whether from this perspective in similar cases the Dutch legislative text really requires the explicit use of e.g.) Now this looks like a legally valid scheme of tax avoidance until the law is changed and this mousehole is closed. It is a usual problem with anti abuse clauses that either they are too narrow and new schemes will escape them or they are too wide and noone knows what they exaclty cover. This is the beauty of the art of taxation :)

interesting video, can i have the remaining part of the case study?

Excelente resumen!!

Thank u

Good analysis. Tax representative is essentially an agent. Tax should only be collected from the agent if the the Tribunal finds that the nonresident (as principal) is taxable in Kenya.

This is interesting case.

Very interesting case Johann. Great video.

Thank you very much for this video - it has been very insightful. Every time I forget about the scope, i always go back to this video.

Very useful explanation. It helped me with an international tax homework!

Did the ADIT Principles of International Taxation course in 2022. Was well worth the money, and I learnt so much from the course. Johann is a very patient instructor and really took the time to help everyone with every single question they had. Highly recommend the course!

Are you still taking suggestions? These would be great: ECLI:NL:HR:2021:1352 ; ECLI:NL:HR:2019:57

Thank for such a great and complex content! However, for such a complicated topic, may it come across to viewers easier with better video and sound quality without sudden loud volume at some points, and less "um" and throat clearing sounds? Just my thoughts! Great videos anyway. Thank for free knowledge sharing, with your time and effort.

As always a vey informatie video again Johann! Thank you for sharing!

On Rolph's benchmarking of Canada's logistical function, he should have used the 30% return on value-added expenses but the fault lied in using a return to total cost approach for the third party logistic companies. For some of his alleged comparables, pass-through costs represented 90% of total costs so doing this right would have meant return to value-added costs that were ten times the reported return to total cost markup.

I listen to your videos every week for inspriration. Please keep up!

thank you for this video!! i still have a question and i it would be very nice if you could help me: whats the difference between the services which could be considered as PE's and the technical services which have different tax rules( i think they could have the rules of royalitites)? thank you in advance

The transfer pricing issue was the intercompany lease payments made by the Canadian entity to the US owners of the barges. I'd be curious how these lease payments compared to what would reasonably be an arm's length payment as the Canadian Revenue Agency could have raised this pricing issue.

Thanks for the discussion of this interesting intercompany factoring issue. There was a larger intercompany guarantee issue in this decision as well. I'm hoping to get up an Edgarstat blog post soon that addresses both of these issues. In my view - the taxpayer's position was not necessarily all that aggressive but the tax authorities make an interesting case that the factoring fee was still above what was arm's length.

Many thanks Johann, I found great insights into your explanation. Looking forward next week video on the interpretation of other concerns.

Hi Johann, hope you're doing well! Great video again!

Thank you. I have understood and practically seeing anti abusive provisions in play . Helpful

The New Zealand IRD could have also challenged the 6.5% interest rate. Given the testimony of its expert witness, this 6.5% rate represented what the arm's length rate should have been for plain vanilla debt but the structure gave the borrower the right to convert debt into equity, which has a value to the borrower. In 3rd party convertible debt transactions the interest rate is generally below the interest rate for plain vanilla debt reflecting the value of this option. This pricing issue came up in a French case involving a loan from the French parent to a UK affiliate for EDF.

The “z” in the great musician’s surname is sounded.

Great explanation though. By the way, cum-driven trades are still possible. I was offered it by last week from the UBS Bank in Switzerland. Don't get involved, unless you live in Dubai mate. What they used to do in Germany was a very messed up way. Some of them forged the tax certificates. How to explain ?! Let's say you get a certificate saying you have the right to be paid back 10.000k. What the fraudsters then did, was just ad another 0 ( zero as digit ) behind the 10.000k. So with forged documents you could get even more money. Still working in Germany, Finnland, Portugal and a few others. Just to let you know in case you want to get involved in these kind of trades.

Thank you for these videos! This is a case study for an assessment I'm doing at the moment and I was struggling to understand all the moving parts. Your visual aids and clear explanations were such a huge help :)

There are two videos on this topic which are actually the same. Is it a mistaken upload? Can you be so kind to pls up the second video on this topic - comparability study that solves this great case study? Thank you!!!

Good analysis. I represented the Tax Authority as Counsel.