Publikationen
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).