Africa

COVID-19 and the future of Pillar one

Oliver Treidler, CEO, TP&C GmbH, Berlin, considers how the COVID-19 crisis will likely affect global negotiations to reform the taxation of multinational groups, noting that a delay could give transfer pricing practitioners time to formulate an alternative, updated, concept of value creation to replace Pillar one’s formulaic elements . . .

Europe

Swedish court rules against Flir Systems, upholds tax penalties of EUR 70 M (USD 76.5 M)

Emiliha Ferrão and Madeleine Thörning, of Thorning Koponen Consulting, Stockholm, discuss a recent Swedish Administrative Court decision in Flir Systems, where the court upheld the Swedish tax agency’s conclusions regarding the tax due on the sale of IP owned by Flir Systems’ Belgium PE to a related Belgian company and also upheld the tax agency’s imposition of significant tax penalties . . .