TP Library

The definitive and up to date library on BEPS and Transfer Pricing is available here.

The definitive and up to date library on Transfer Pricing in Canada is available here.

The definitive and up to date library on Transfer Pricing in the United States is available here.

To see other countries’ transfer pricing regulations, go to the OECD Transfer Pricing Country Profiles available here.

The Joint Transfer Pricing Forum of the European Union also maintains Member States’ Transfer Pricing Profiles which are available here (scroll down to section 2 in hyperlink).

The OECD Transfer Pricing Guidelines play a central role in transfer pricing around the world. The OECD Transfer Pricing Guidelines published in July 2017 are available online at www.keepeek.com.

Numerous changes have been made since 2010 (see the BEPS Library here).

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Selected Publications

Robert Robillard: “Contractual Arrangements and the Delineation of a Transaction: A Duo in Crisis Mode”, Intertax, Volume 45, Issue 12, December 2017, Wolters Kluwer, pp. 801-06.

Robert Robillard: ““Profits” in Profit Split Methods: Hazardous Crossovers on the way to Global Formulary Apportionment”, Tax Notes International, October 9, 2017, Tax Analysts, pp. 167-73.

Robert Robillard: “Canada’s Approach to Implementing OECD Documentation Rules”, Tax Management Transfer Pricing Report, Vol. 25, No. 14, October 5, 2017, The Bureau of National Affairs Inc., pp. 532-28; http://www.bna.com.

Robert Robillard: “Attribution of Profits to Permanent Establishments: It is time for Convergence”, Tax Topics No. 2376, September 21, 2017, Wolters Kluwer, pp. 1-3. Reproduced with permission. Published and copyright Wolters Kluwer Canada Limited.

Robert Robillard: “Profit-Split Methods and the OECD: Leaning Toward Formulary Apportionment?”, Tax Notes International, Sept. 4, 2017,  Tax Analysts, pp. 1005-1011 (reproduced with permission).

Robert Robillard: Comments on the Public Discussion Draft BEPS Action 7: Additional Guidance on Attribution of Profits to Permanent Establishments, OECD Public Discussion Draft (August 23, 2017).

Robert Robillard: Consultations sur des propositions législatives fiscales : Planification fiscale au moyen de sociétés privées (French) (August 22, 2017).

Robert Robillard: Comments on the Public Discussion Draft BEPS Action 10: Revised Guidance on Profit Splits, OECD Public Discussion Draft (August 21, 2017).

Robert Robillard: Comments on Draft Contents of the 2017 Update to the OECD Model Tax Convention, OECD Public Discussion Draft (August 1st, 2017).

Robert Robillard: “Country-by-Country Reporting in Canada and the United States : A Comparison”,  Tax Management Transfer Pricing Report, Vol. 25, No. 14, November 24, 2016, The Bureau of National Affairs Inc., pp. 856-59; http://www.bna.com (reproduced with permission).

Robert Robillard: Consultation du gouvernement du Canada sur des propositions législatives fiscales : la déclaration pays par pays (article 233.8) (French) (September 26, 2016).

Robert Robillard: “Is There a Sixth Comparability Factor in Canadian Transfer Pricing?“, Canadian Tax Journal, Canadian Tax Foundation, Vol. 63, No. 2, pp. 375-95 (first published by the Canadian Tax Foundation in (2015) 63:2 Canadian Tax Journal 375-95; reproduced with permission).

Robert Robillard: “BEPS-Flavored Cost Contribution Agreement Leave a Sour Aftertaste“, Tax Notes International, July 6, 2015, Tax Analysts, pp. 1115-19 (reproduced with permission).

Robert Robillard: « Les nouvelles règles internationales de documentation de prix de transfert de l’OCDE » Magazine Stratège, Association de planification fiscale et financière (APFF), Juin 2015, Vol. 20, No. 2, pp. 44-48; http://www.apff.org (reproduced with permission).

Robert Robillard: “BEPS Action 3 Missing in Action: CFC Rules or Global Formulary Apportionment?”,  Tax Management Transfer Pricing Report, Vol. 24, No. 3, June 11 2015, The Bureau of National Affairs Inc., pp. 172-75; http://www.bna.com (reproduced with permission).

Robert Robillard: “Finding its Way on a Foggy Moonless Night: Measuring BEPS“, Tax Notes International, June 1, 2015, Tax Analysts, pp. 823-27 (reproduced with permission).

Robert Robillard: “BEPS: Is the OECD Now at the Gates of Global Formulary Apportionment?”Intertax, Volume 43, Issue 6/7, Wolters Kluwer, pp. 447-53 (reproduced with permission).

Robert Robillard: Comments on Public Discussion Draft BEPS Action 11: Improving the Analysis of BEPS, OECD Public Discussion Draft (May 7, 2015).

Robert Robillard: Comments on Public Discussion Draft BEPS Action 3: Strengthening CFC Rules, OECD Public Discussion Draft (May 1st, 2015).

Robert Robillard: Comment on Public Discussion Draft BEPS Action 12: Mandatory Disclosure Rules, OECD Public Discussion Draft  (April 29, 2015).

Robert Robillard: “Canada’s TPM-15 and TPM-16: Throwing Sand in the BEPS Gears“, Tax Management Transfer Pricing Report, Vol. 23, No. 23, April 02 2015, The Bureau of National Affairs Inc., pp. 1535-37; http://www.bna.com. (reproduced with permission).

Robert Robillard: Comments on Public Discussion Draft BEPS Action 10: Use of Profit Splits in the Context of Global Value Chains, OECD Public Discussion Draft (February 5, 2015).

Robert Robillard: Comments on Public Discussion Draft BEPS Actions 8, 9 and 10: Revisions to Chapter I of the Transfer Pricing Guidelines (Including Risk, Recharacterisation, and Special Measures), OECD Public Discussion Draft (February 4, 2015).

Robert Robillard: Comments on Public Discussion Draft BEPS Action 10: Transfer Pricing Aspects of Cross-Border Commodity Transactions, OECD Public Discussion Draft (February 3, 2015).

Robert Robillard (RBRT): Comments on Public Discussion Draft BEPS Action 14: Make Dispute Resolution Mechanisms More Effective, OECD Public Discussion Draft (January 14, 2015).

Robert Robillard (RBRT): Comments on the Public Discussion Draft BEPS Action 7: Preventing the Artificial Avoidance of PE Status, OECD Public Discussion Draft (January 8, 2015).

Robert Robillard (RBRT): Comments on Public Discussion Draft on BEPS Action 10: Proposed Modifications to Chapter VII (Low-Value Adding Services), OECD Public Discussion Draft (January 13, 2015).

Robert Robillard: « BEPS: A Transfer Pricing Documentation Survival Kit for Small and Medium-Sized Businesses »,Transfer Pricing International Journal, Vol. 15, Issue 12, December 2014, Bloomberg BNA, pp. 4-9; http://www.bna.com/ (reproduced with permission).

Robert Robillard: « Prix de transfert et efforts sérieux au Canada : où en sommes-nous? » Magazine Stratège, Association de planification fiscale et financière (APFF), Décembre 2014, Vol. 19, No. 5, pp 32-34; http://www.apff.org. (reproduced with permission).

Robert Robillard: « When It Rains, It Pours: Changes to TP Documentation in Canada May Create a Perfect Storm for Taxpayers », Transfer Pricing International Journal, Vol. 15, Issue 11, November 2014, Bloomberg BNA, pp. 7-12;http://www.bna.com/. (reproduced with permission).

Robert Robillard: « Affaire Marzen Artistic Aluminum – La validité d’un prix de transfert n’est pas déterminée par le résultat obtenu », Revue de planification fiscale et financière, Vol. 34, No. 4, Novembre 2014, Association de planification fiscale et financière (APFF)http://www.apff.org. (reproduced with permission).

Robert Robillard: Comments on the Public Discussion Draft BEPS Action 11: Establish methodologies to collect and analyse data on BEPS and the actions to address it, OECD Public Discussion Draft  (September 17, 2014).

Robert Robillard: Consultation prébudgétaire fédérale du Canada 2015 (French) (August 1, 2014).

Robert Robillard: Consultation du gouvernement du Canada sur la fiscalité internationale (French) (June 6, 2014).

 

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