Yves Hervé and Philip de Homont of NERA Economic Consulting discuss transfer pricing solutions in situations where multiple entities make unique and valuable contributions to a business.
Yves Hervé, Philip de Homont and Salem Saljanin of NERA Economic Consulting discuss the transfer pricing challenges that multinational automotive suppliers increasingly face and present innovative solutions in a post-BEPS setting.
Yves Hervé and Philip de Homont of NERA Economic Consulting discuss plans for an alternate proactive strategy to defuse TNMM benchmarking-related tax controversies on audits in Germany.
Yves Hervé and Philip de Homont of NERA Economic Consulting discuss the potential impact of the key changes proposed in the German Ministry of Finance’s transfer pricing administrative guidelines.
Yves Hervé and Philip de Homont of NERA Economic Consulting present a case study on considering the data-based economic valuation of user contributions.
Niraja Srinivasan, Yves Hervé and Philip de Homont of NERA Economic Consulting take a closer look at the transfer pricing challenges and solutions that have emerged from restructuring expenses during the coronavirus pandemic.
Yves Hervé and Philip de Homont of NERA Economic Consulting explain how multinationals can plan to mitigate losses faced in their manufacturing transfer pricing model.
Yves Hervé and Philip de Homont of NERA Economic Consulting assess how companies can suitably address concerns surrounding transfer pricing (TP) license agreements.
ITR European Tax Awards winners Yves Hervé and Philip de Homont of NERA Economic Consulting talk about the evolving European TP landscape and the COVID-19 impact on client work in a podcast.
Yves Hervé and Philip de Homont of NERA Economic Consulting present a real-life case study explaining how the correct transfer pricing techniques can somewhat alleviate the harsh economic effects of the pandemic.
Yves Hervé and Philip de Homont of NERA Economic Consulting analyse how the economic decline caused by the coronavirus outbreak may prompt multinationals to alter their transfer pricing models.
Managing Director Yves Hervé and Associate Director Philip de Homont of NERA Economic Consulting explain how, and under which circumstances, cost-plus solutions for contract R&D arrangements can be sustained in a post-BEPS age.
Yves Hervé and Philip de Homont of NERA Economic Consulting show how taxpayers can adapt their defence strategies to the DEMPE concept, focusing particularly on the use of third-party agreements.
It is likely that many tax disputes will arise from the new definition of hard to value intangibles (HTVI) in the OECD's transfer pricing (TP) guidelines.
In our last article, we described the challenges that the digital transformation poses for transfer pricing (TP). In this article, we want to show how emerging business interdependencies can be translated into new TP models.
This article describes the challenges that the digital transformation of the economy poses for transfer pricing. In the next article of the series, it will show how these interdependencies can be translated into new transfer pricing models.
The combined effect of the globalisation of entrepreneurial responsibilities within multinationals and the OECD's BEPS initiative puts traditional one-sided transfer pricing (TP) methods under increased pressure. NERA Managing Director Dr Yves Hervé and Associate Director Philip de Homont show how transactional net margin method (TNMM)-type TP solutions can be made sustainable for the future.
In a previous article in this series, we described the necessity of rethinking transactional net margin method (TNMM) studies and enhancing them with economic analysis. NERA Economic Consulting Managing Director Yves Hervé and Associate Director Philip de Homont describe how economic adjustments can be used to improve the quality of benchmarking analyses.
In TP audits around the world, tax authorities are starting to use the development, enhancement, maintenance, protection, and exploitation of intangibles (DEMPE) concept that was recently established by the OECD.