Photo of Astrid Pieron

Astrid Pieron's practice covers counseling on the transactional aspects of transfer pricing, tax optimization of mergers and acquisitions, structuring of investment funds and general assistance to private equity deals.

Astrid is heading the Mayer Brown European transfer pricing center that coordinates transfer pricing strategies and controversies in Europe. She served as a non governmental member to the EU Joint transfer pricing Forum advising the EU commission on transfer pricing matters (2012-2015). She currently serves as a Member of the EU Platform for Good tax Governance advising the EU commission on the BEPS implementation.

Continue Reading

This week is a busy week for the digital industry. The EU Court of Justice is closing two cases involving digital-economy giants. At the same time, the EU Commission released its new Tax Package covering three separate but related initiatives: a Tax Action Plan (25 distinct actions) to make taxation “simpler, fairer and better attuned to the modern economy over the coming years,” a proposal on administrative cooperation (“DAC 7”) extending EU tax transparency rules to digital platforms, and a Communication on tax good governance proposing a reform of the Code of Conduct, which addresses tax competition and tackles harmful tax practices within the EU. DAC 7 and the new transparency rules will directly impact the digital industry.

Continue Reading The Digital Industry in the EU Spotlight

Many multinational enterprises (“MNEs”) are providing new forms of financial, technical, or other support to group members facing COVID-19-related business issues such as plant (temporary) closures or supply chain disruptions. This support may in some cases give rise to a transfer of value, such as the knowhow of a seconded employee. It may also involve a transfer of assets coupled with the ability to perform certain functions and assume certain risks. Such transfers could be viewed as a “business restructuring” as defined by the Chapter IX of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017) (the “OECD Guidelines”) and may trigger transfer pricing and tax consequences.

Continue Reading Support Among Group Members in Time of COVID-19