A quantitative survey of the allocation keys cited in the 140 contributions to the OECD consultation on Chapter VII of the Transfer Pricing Guidelines. The note maps the keys most frequently associated with each of 14 business functions, based on 1,219 coded mentions.

A content analysis of the 140 submissions received by the OECD on the proposed revision of Chapter VII of the Transfer Pricing Guidelines. Using a structured coding of 91 technical positions, the note maps where explicit industry support aligns with — or departs from — expectations.

An analysis of the French criminal investigation into McKinsey's transfer pricing arrangements and the resulting EUR 200 million tax reassessment.

A review of who contributed to the OECD's public consultation on the revision of Chapter VII of the Transfer Pricing Guidelines on intra-group services.

An analysis of two pending CJEU cases (Högkullen and Arcomet) examining how VAT rules interact with transfer pricing adjustments within the European Union.

A review of the application of the OECD's Authorised OECD Approach for attributing profit to permanent establishments in France, following the Hypo and Conversant case law.

An assessment of the potential impact of the 2024 U.S. election outcome on transfer pricing and tax policy for French and European multinational groups.

A framework for analysing the transfer pricing treatment of corporate CSR/ESG initiatives within multinational groups, based on four distinct cost components.

A commentary on the Apex ruling and its implications for the deductibility of interest on intra-group financing arrangements in France.

Comments submitted as the France country panelist to the Bloomberg Tax Transfer Pricing Forum on patent boxes and related R&D tax incentives.

Comments on the joint IMF-OECD-UN-World Bank toolkit for addressing transfer pricing challenges faced by developing countries.

An analysis of the tension between the European Commission's state aid case against Apple and its proposal for a Common Consolidated Corporate Tax Base.

Comments submitted to the OECD's public consultation on proposed revisions to Chapter VII of the Transfer Pricing Guidelines on intra-group services.

Comments submitted to the OECD/IGF public consultation on the transfer pricing aspects of critical minerals, focusing on copper.

Comments submitted to the OECD's 2019 public consultation on addressing the tax challenges raised by the digitalisation of the economy.

Comments submitted to the OECD on the implementation guidance for hard-to-value intangibles under BEPS Action 8.

Comments on the OECD's discussion draft guidance on hard-to-value intangibles under BEPS Action 8, part of the broader transfer pricing framework for intangibles.

Comments submitted to the OECD's 2017 discussion draft on the attribution of profits to permanent establishments.

Comments submitted to the OECD on additional guidance for the attribution of profits to permanent establishments under BEPS Action 7.

Comments submitted to the OECD on the revised guidance on the transactional profit split method under Chapter IX of the Transfer Pricing Guidelines.

Comments submitted to the OECD on the discussion draft proposing modifications to Chapter VII of the Transfer Pricing Guidelines relating to low value-adding intra-group services.

A chapter covering transactional profit methods and other transfer pricing methods, part of the leading academic reference textbook on transfer pricing.

A chapter covering transactional profit methods and other transfer pricing methods, part of the leading academic reference textbook on transfer pricing.

A chapter covering transactional profit methods and other transfer pricing methods, part of the leading academic reference textbook on transfer pricing.

A self-published techno-thriller novel about artificial intelligence and cyberwarfare, unrelated to transfer pricing.