Transfer Pricing Aspects of Pillar One and Pillar Two

This article showcases the potential interplay between transfer pricing rules and the OECD’s Pillar One and Pillar Two proposals.Given their simultaneous application,conflicts between these sets of rules may arise.The article also emphasizes the importance of careful consideration before implementation of these rules,including potential adjustments to domestic laws,and the need to prevent double taxation and less-than-single taxation risks through enhanced cooperation and clear communication.

Generative AI:The Power Behind Large Language Models and Its Use in Tax Administration

This article examines the potential of Generative Al to transform the operation of tax systems and the potential barriers that will have to be overcome.It is intended to start a conversation amongst BRI tax administrations on the areas where Al could have the greatest impact on taxpayer service and compliance.

The Potential of Blockchain to Transform Tax Systems in BRI Jurisdictions

This short article sets out how technology is able to help resolve some of the basic problems that have plagued Belt and Road Initiative economies over many decades,namely:how to assist companies to take advantage of global markets;how to move away from a cash-based economy to a cashless economy;and how to deal with the growing volume of illicit financial flows.These technologies will transform the tax administrations of BRI jurisdictions over time.

A study on population dynamics in“Belt&Road”countries and their implications

China’s Belt&Road(“B&R”)initiative has attracted much attention in recent years.Many studies have assessed the potential impacts of this initiative from the economic,political,foreign relations,and military perspectives.However,very little attention has been paid to examine the opportunities and challenges of this new initiative from a demographic perspective.Therefore,this study investigates into the population dynamics of 65 countries in the B&R region,and explores the demographic dynamics of this regional cooperation model.Based on graphic visualization,the demographic heterogeneities within the B&R region,in terms of current stages of demographic transitions,population age structure,and demographic windows of opportunities have been revealed.Furthermore,a model-based cluster analysis has been conducted to classify the B&R countries into two groups.One group consists of countries with younger population,low education access,and larger gender gap in the labor market,while the other group comprises of more aged population and has better performances in economic development,education enrolment,and female labor participation.The demographic windows of opportunities in the former group will remain open for the coming decades;whereas the windows have already closed or is about to close very soon in the latter group.The former group should take lessons from the latter concerning how to better prepare themselves for the demographic transition.Moreover,the curvilinear relationship between wealth and well-being has a complicated structure and the B&R initiative should focus not only on economic development but also on the human well-being.

New Technologies and Transfer Pricing in the BRI Jurisdictions

This paper explores the linkage between emerging new technologies and transfer pricing,and the mechanisms available to minimise and resolve disputes in this area.It explores the way that these technologies can help achieve a better application of the Arm’s Length Principle(ALP)which remains the bedrock for transfer pricing around the world.It also identifies the way that both MNEs and Tax Administrations can use these technologies to get access to more comparable information and to achieve greater consistency in the allocation on the basis of the ALP.Finally some new ways of achieving more effective cross-border resolution mechanisms in the BRI jurisdictions are explored.