This TP Talks episode features an in-depth discussion between Kartikeya Singh (Principal, PwC US Washington National Tax Services), Giorgia Maffini (Senior Manager, TP and Tax Policy – PwC UK) and Stefaan De Baets (Senior Manager, TP, PwC Belgium), of the October 12 OECD Blueprint on Pillar One, focusing on important considerations with regard to scoping, sourcing rules, and segmentation — when to segment, how to segment. The speakers also focus on the uncertainties surrounding the arm’s-length principle, and fixed returns for routine marketing and distribution activities. Finally, the speakers discuss open items, including dispute resolution options.
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