Freelance Tax Specialist
Temporary Support, Sustained
Benefits.
About me
Bram Markey
Hi!
I'm an independent freelance tax specialist, providing tax support and flexible tax management solutions for companies that are in need of helping hands. Even though the support may be temporary, my commitment is to make the benefits lasting for your organisation.
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I have over 15 years of practical experience working with a range of businesses, ranging from small to large multinational enterprises at PwC. I have deep transfer pricing and international corporate tax expertise in a variety of industries.
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I'm a seasoned project leader that succesfully managed multiple business transformation and simplification exercises in Europe, including alignment of corporate tax, VAT, customs, operational, accounting & legal workstreams. My industry experience includes: Food & Beverages, FMCG, Industrial Manufacturing, Retail, Pharma & Lifesciences and Chemicals.
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Are you facing a challenging tax audit or specific tax risks? I can help prevent, manage and resolve tax disputes in many EU countries leveraging my network as former leader of PwC’s EMEA Tax Controversy & Dispute Resolution practice.
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Bringing talent to the next level is one of my passions.
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I look forward to teaming up with your organisation!
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Bram
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Services
Are you looking for interim replacement within your tax function? Are you facing challenging tax audits or are you simply in need of support for managing specific tax projects?
Bram provides flexible solutions at competitive rates.
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Bram works in sync with your team and preferred advisor(s) depending on the agreed scope and nature of the project.
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Contact me to find out more!
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Project management experience in the field of intellectual property planning, operating model transformation, restructurings, supply chain reconfiguration, establishment of tax control frameworks, integration of acquisitions, simplification of corporate structures, Pillar 2 compliance, multilateral tax audits and branch models.
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International Tax Review
Get in touch
Bram Markey BV
Kruisbulckstraat 28
9800 Deinze
Belgium
BE 0784.813.835
+32 473 79 46 78
Reconized ITAA Tax Consultant
n° 52.388.686
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Insights
My recent publications
Eligibility for Mutual Agreement Procedure under Tax Treaties Following Application of the Principal Purpose Test
IBFD, Bulletin for International Taxation · Vol. 76 / 2022
with T. Gisquière
The principal purpose test (PPT) can result in the denial of treaty benefits to taxpayers. This article sets out why the application of the PPT should not prevent eligible taxpayers from initiating a request for a mutual agreement procedure (MAP) to resolve taxation or interpretation issues relating to the PPT.
Value creation analysed through the transfer pricing lens
Fixed Establishments and Permanent Establishments: The VAT and Direct Tax Concepts Are Drifting Further Apart
IBFD, International VAT Monitor · Vol. 27 / 2016
with I. Lejeune and A. Baltus
The notion of permanent establishment (PE) from a direct tax perspective changed following BEPS and the MLI. This does however not imply that the VAT threshold for a fixed establishment (FE) has been lowered. In this article, both concepts are analyzed based on recent OECD guidance and the ECJ’s VAT case law. A fact pattern will increasingly lead to different qualifications from a VAT and corporate tax perspective despite the fact that tax authorities try to argue otherwise.
Wolters Kluwer, Intertax · 44 / 2016
with I. Verlinden
The IoT, powerful corporate identities, innovative ways to play the market and an increasing reliance on intangibles are vital elements that lead to unprecedented ways of ‘value creation’. Tax practitioners often grapple with interpreting and translating value creation under innovative business models of multinational enterprises to the transfer pricing dictionary. This publications clarifies means of examples how successful companies nowadays create value and unlock ‘economic rent’ across the value chain and how a 'Value Chain Analysis' can be performed.
A few noteworthy takeaways from the Belgian direct tax controversy environment
ITR World Tax · 2020
with V. De Brabanter
A number of recent developments in the international tax world are finding their way into the Belgian tax investigation practice. We have observed a significant increase in domestic and multilateral tax audits, including field inspectors increasingly having recourse to means of international exchange of information and anti-abuse legislation to build their claims. On top of the annual wave of transfer pricing investigations, Belgian tax audits focus more and more on passive income flows (dividend, interest and royalty), beneficial ownership issues and alleged tax abuse through the involvement of intermediary entities. Entities that have significant carry-forward tax losses or high debt leverage are also facing a lot of scrutiny in Belgium. This article provides insights in these developments in tax audits and case law.
EU kondigt project aan over “cooperative compliance” inzake verrekenprijzen
Internationale Fiscale Actualiteit 9 / 2021
with S. De Baets
The European Commission published guidelines on the “European Trust and Cooperation Approach” (ETACA), a pilot project on “cooperative compliance” within the EU, specifically aimed at transfer pricing risks for large multinationals. This article provides insights on this new programme aimed at preventing transfer pricing disputes.
Beslechting belastinggeschillen in EU: nieuwe procedure sinds 1 juli
Internationale Fiscale Actualiteit · 7 / 2016
with V. De Brabanter , L. Cassimon, G. Van Hulle
Directive (EU) 2017/1852 of 10 October 2017 on tax dispute settlement mechanisms in the European Union has been transposed into Belgian domestic law. This article sets out how the steps and functioning of this new procedure and how it can help to resolve international tax disputes more effectively.
“Back to the future?” – Belgian Court rules that DEMPE concept cannot be applied retroactively
Kluwer International Tax Blog · 2021
with R. Devroye
In a recent judgement, the Belgian Court of Appeal of Ghent ruled in favour of the taxpayer as regards a transfer pricing case in relation to intangibles. Even though the case is complex with a number of factual and procedural twists, the Court made a number of explicit and noteworthy statements on whether or not the OECD Transfer Pricing Guidelines (“TPG”) can be applied in an ambulatory way while interpreting and enforcing the arm’s length principle. The Court of Appeal of Ghent considered that the DEMPE concept not to be a mere clarification and hence it cannot be applied retroactively.
Proefproject rond ‘Co-operative Tax Compliance’ aangekondigd
Fiscale Actualiteit 36 / 218
with B. Seys and S. De Baets
The Belgian tax authorities launched a pilot project on 'co-operative tax compliance'. The aim is a reform of traditional ex-post tax audits towards a system of proactive, real-time and constructive dialogue on corporate tax matters under the name 'Co-operative Tax Compliance Program' (CTCP). This article sets out how the new programme works.