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Vladimir Zivkovic

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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.

The tax challenges of the digital economy may catch historically non-digital companies by surprise as they “go digital.” Baker McKenzie’s Special Report, Digital Revolution: Transfer Pricing on the Global Tax Battlefield 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, transfer pricing considerations, multilateral and unilateral measures, transfer pricing audits and dispute resolution.

On 14 and 15 January 2021, the OECD held a public consultation to address comments received from the public on the Draft Pillar 1 and Pillar 2 Blueprints (available here). The first day of the two-day consultation, which was held via video conference, addressed feedback received from stakeholders (businesses, trade associations, academia and NGOs) in December of 2020 on the Pillar 1 Blueprint. The OECD also provided an update on the state of play, with confirmation that the Inclusive Framework goal remains to reach a consensus political agreement by July of 2021. While the participants echoed the broad support among businesses and organizations for an international consensus-based solution, it is clear following the January 14 consultation that substantial work lies ahead before a Pillar 1 agreement is reached, and thereafter further work to draft the necessary multinational agreements and obtain national agreement before it can be successfully implemented across a meaningful number of jurisdictions. Below, we examine the key take-aways from the consultation on Pillar 1.

Global supply chains across all industry sectors are facing an unprecedented challenge due to the COVID-19 pandemic. Increased pressure on supply chain linkages is nothing new to multinational enterprises (MNEs), due to national tax and trade protectionism measures, evolving international tax policies, and technological disruption, but the current global pandemic…