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The tax challenges of the digital economy may catch historically non-digital companies by surprise as they “go digital.” Are you prepared?

Baker McKenzie’s Special Report, Digital Revolution: Transfer Pricing on the Global Tax Battlefield, produced in partnership with Bloomberg Tax and Accounting, provides insight into digital technology trends non-digital businesses are incorporating and the key tax trends companies must actively navigate including:

  • Industry sector case studies and transfer pricing considerations
  • Multilateral and unilateral measures
  • Transfer pricing audits and dispute resolution

As you review and have questions, please contact your Baker McKenzie team or any of the authors of this report.DOWNLOAD REPORT

This Special Report was first published by Bloomberg Tax and also appeared in the Tax Management International Journal, June 2021.

Author

Armando Cabrera-Nolasco is a partner in Baker McKenzie's Tax Practice Group in Guadalajara. He has 10 years of experience in transfer pricing issues. Mr Cabrera-Nolasco currently coordinates the transfer pricing services for financial and services industries, and the financial valuation practice.

Author

Bruno Dominguez is a partner and head of theTax practice in Barcelona and Chair of our Wealth Management Practice in Europe, Middle East and Africa. Bruno has been coordinator of the Master of Laws in Taxation at the University of Barcelona, and associate professor at ESADE Business School. He has written several articles and regularly speaks at conferences and seminars on business restructuring, transfer pricing, wealth management and taxation of family businesses.

Author

Tamara Levin is a partner in Baker McKenzie’s San Francisco/Palo Alto Tax Practice Group. She regularly advises companies, mostly in technology-based industries, on transfer pricing and tax planning matters, including structuring and implementing international operations, cross-border transactions, and post acquisition integrations. Tamara speaks at internal workshops and seminars, as well as external events sponsored by Bloomberg BNA and the Tax Executives Institute.

Author

Dr. Carlos Alberto Linares Garcia is a principal economist of Baker McKenzie’s Latin America Transfer Pricing practice. He is knowledgeable in the fields of transfer pricing, financial valuation and antitrust. His professional experience includes more than 13 years in consulting and three years in the public sector. From 1993 to 1995, Dr. Linares was a deputy director with the International Tax Department of the Mexican Ministry of Finance in Mexico City. From 1996 to 1999, he was an associate economist at Houston-based Baker & Associates Energy Consultants and from 2000 and 2004, he was a senior manager and a partner in the energy economics and transfer pricing group at a big-four firm in Houston and Monterrey. Dr. Linares received the Banamex Economics Award in 2000, as well as the Inter-American Social Security Award in 2002. He has lectured at various institutions such as the IFBD, Rice University, Universidad Autónoma de Nuevo León and the Tecnológico de Monterrey.

Author

Amanda Kottke advises domestic and international enterprises from a wide range of industries on US federal income tax issues, with a focus on resolving complex tax disputes and international tax controversies. She writes and speaks frequently on international tax topics related to global tax dispute resolution, privilege, and transfer pricing considerations.

Author

In her role as Principal Economist in the Firm’s Transfer Pricing Practice Group, Michelle Martinez leads the Chicago-based team of economists in providing multinational companies with economic analyses and valuations to assist them in preparing transfer pricing support for jurisdictions around the world. A particular focus of Ms. Martinez’s practice has been the structuring and valuation of intercompany transactions of intangible property, assisting clients with licensing, cost-sharing and business reorganizations. International Tax Review as a Leading Practitioner in their annual Women in Tax Leaders Guide (2016-2019).

Author

Donna McComber is a director of economics for Baker McKenzie Consulting LLC in Washington, DC. She is a seasoned transfer pricing advisor with deep technical insight into complex transfer pricing issues. Prior to rejoining Baker McKenzie, Ms. McComber was assistant director of the Advance Pricing and Mutual Agreement Program (APMA) under the US Internal Revenue Service's Large Business & International Division. She managed teams that were responsible for cases in the following countries: Argentina, Caribbean countries, China, Denmark, Eastern European countries, Germany, India, Ireland, Israel, Mexico, Portugal, Norway, Spain, Sweden, Switzerland, UK and Venezuela. Prior to becoming assistant director, she was the deputy director (technical) and reviewed US positions and negotiated APA MAP cases with treaty partners including Australia, Canada, China, Denmark, Germany, Japan, Mexico, Korea, Switzerland, and the UK. Prior to the IRS, Ms. McComber was a senior economist with Baker McKenzie.

Author

Andrew O'Brien-Penney is a director of economics in Baker & McKenzie Consulting LLC in Chicago. He has experience in transfer pricing and valuation matters, assisting major multinational companies on a variety of engagements, including advising clients in audit and dispute resolution situations, supply chain restructuring, planning, advance pricing agreements (APAs), and intellectual property migration opportunities. Andrew's experience covers several industries including pharmaceuticals, medical devices, financial services and automotive.

Author

Dr. Nikolaus Reinhuber has more than 25 years' experience in cross-border transactions and is the Global Chair of the Industrials, Manufacturing and Transportation (IMT) industry group in Baker McKenzie’s office in Frankfurt. Clients have described him as "statesmanlike, with real interpersonal skills, who strikes the right note at 3 a.m. and gets the deal to the finish line" as well as "excellent work and extremely strong dedication" (JUVE 2014/2015). Before joining Baker McKenzie in 2008, he served as an M&A and corporate partner with Freshfields Bruckhaus Deringer, where he also held a global management position. Dr. Reinhuber has also acted as a supervisory board member of listed companies and advised them on their IPOs.

Author

Hub Stolker is a tax adviser and lawyer in Baker McKenzie's International Tax Practice Group in Amsterdam. In addition to advising on general corporate tax law, he also represents multinational enterprises in transfer pricing, cross-border business restructurings, supply chain optimization, double taxation avoidance, mutual agreements procedures and tax-related arbitration. Hub frequently publishes articles on tax in BNA magazine and leads internal transfer pricing technical sessions. He has also conducted lectures at the Maastricht University and various conferences.

Author

Gene Tien works with US and foreign multinationals on transfer pricing (TP) and other economic valuation issues, with a primary focus on the planning and dispute resolution of intangible property (IP) transactions and other value-added TP flows. Dr. Tien also works on economic development issues on a pro bono basis — including international fiscal devolution, water rights, and domestic social justice research. He regularly presents and writes about developments in international TP policy.

Author

Antonio A. Weffer is a tax principal in Baker McKenzie's Tax Practice Group and the head of the firm's transfer pricing practice in Luxembourg. Antonio is an active member of several international professional tax organizations, and regularly publishes articles on international tax issues and speaks at worldwide seminars and conferences. He was ranked Band 2 in the World Transfer Pricing 2017 guide.

Author

Vladimir Zivkovic is a senior economist in Baker McKenzie Amsterdam’s Transfer Pricing team. He has more than nine years of experience in transfer pricing and value chain analysis. Vladimir started his career in Canada and relocated to the Netherlands in 2011.

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