[Translate to English:] Ansicht Campus WU

Publications

Articles in journals:

  • A look into the future of tax systems (with J. Owens), Tax Notes International (2021), forthcoming.

  • Balancing tax transparency and tax certainty: Reporting obligations for unilateral safe harbours under DAC 6, Intertax (2021), forthcoming.

  • Using Safe Harbors to Simplify the Application of the Arm’s-Length Principle (with D. Kovacs), Tax Notes International (2021), 727.

  • COVID-19 Impact on TP Analysis – Treatment of Expenses, IFA India Newsletter (November 2020, Issue 9).

  • Developing a transfer pricing policy framework for the current economic crisis and beyond (with S. Prasanna), IBFD International Transfer Pricing Journal (2020), v. 27, n. 5, 326.

  • Tax Crimes as Predicate Offences in the EU Sixth Anti-Money Laundering Directive, IBFD European Taxation (2020), v. 60 n. 9, 394.

  • Using Arbitration to Resolve Transfer Pricing Disputes and the Impact of the OECD's Unified Approach Proposal", Tax Notes International (2020), v. 97, 1261.

  • Recharacterization of Intra-Group Commodities Transactions - Review of Case Glencore Investment Pty Ltd v. Commissioner of Taxation of the Commonwealth of Australia, Transfer Pricing International (2020), v. 1, 44.

  • Simplifying the Transfer Pricing Analysis: An Illusory Chimaera or a Realistic Ambition? (with R. Petruzzi), World Tax Journal (2019), v. 11 no. 4, 531.

  • Treatment of Currency Losses and Interest-Free Loans Under the Dutch Participation Exemption – Review of Case 17/03918 of the Supreme Court of the Netherlands, Transfer Pricing International (2019), v. 4.

  • The OECD “Unified Approach” - Have the Cards Been Reshuffled? (with Petruzzi, R. et al.), Transfer Pricing International (2019), v. 6.

  • Global Transfer Pricing Conference 2019: Transfer Pricing Developments around the World, IBFD International Transfer Pricing Journal (2019), v. 27 n. 5.

Contributions to books:

  • Transfer Pricing in Brazil (with A. Costa Chaves), Petruzzi/Cottani/Lang eds., Fundamentals of Transfer Pricing: Specific Industries, Regions/Countries, Intersection with Other Disciplines and Use of New Technologies, Wolters Kluwer (2022), forthcoming.

  • Use of New Technologies in Transfer Pricing by Tax Administrations (with S. Yuan Yong), Petruzzi/Cottani/Lang eds., Fundamentals of Transfer Pricing: Specific Industries, Regions/Countries, Intersection with Other Disciplines and Use of New Technologies, Wolters Kluwer (2022), forthcoming.

  • Transfer Pricing and Financial Transactions (with D. Kovacs), Petruzzi/Lang eds., Transfer Pricing Symposium: Transfer Pricing and Financial Transactions, Linde (2022), forthcoming.

  • Transfer Pricing Methods (Part II): Transactional Profit Methods (with G. Madelpuech), Petruzzi/Cottani/Lang (eds.), Fundamentals of Transfer Pricing: General Topics and Specific Transactions, Wolters Kluwer (2021), forthcoming.

  • Tax Treaty Application beyond the Scope of Article 2 OECD Model Convention 1982 and 2017 (Mutual Agreement, Non-Discrimination, Mutual Assistance) (with A. Rust & X. Luo), Kofler et al. eds., Taxes Covered under Article 2 of the OECD Model: The Scope of Tax Treaties in a Dynamic Global Environment of Newly Created Taxes, IBFD (2021), 263.

  • Profit Attribution to Agency PEs (Art 5 para 5 and 6) – Panel Discussion, Lang/Storck/Petruzzi (eds.), Attribution to Profits to Permanent Establishments, Linde (2020), 139.

  • Global Transfer Pricing Developments, in Transfer Pricing Developments Around the World 2019, Lang/Petruzzi/Storck (eds.), Alphen aan den Rijn: Kluwer Law International (2019).

Comments to international organisations

  • Comments on transfer pricing issues relating to the design of safe-harbour provisions and other comparability considerations, OECD (2020) (with D. Kovacs, S. Prasanna, R. Petruzzi).

  • Comments on the roadmap of the proposal entitled “Tax fraud and evasion – better cooperation between national tax authorities on exchanging information”, European Commission (2020) (with Jeffrey Owens).

  • Comments on the Secretariat Proposal for a “Unified Approach” under Pillar One, OECD (2019) (with R. Petruzzi, R. Holzinger, M.S. Screpante, S. Buriak).

  • Comments on the new Chapter IV of the TPG, "Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes", OECD (2018) (with A. Storck, J. Owens, R. Petruzzi).

  • Comments to OECD on the Public Discussion draft on BEPS Actions 8-10 - Financial Transactions, OECD (2018) (with A. Storck, R. Petruzzi, S. Prasanna).