Hello everyone. Welcome to the next episode of our Taxbyte podcast. Today we will talk about

the future of work. In the current time when vaccines are being distributed, people start to think

of how we will work in the new normal.

Recently, a Belgian multinational company even already announced that a significant part of the time employees will be working from home also in the future.

This company will even reduce the available office space.

So time to think about the broader impact of all of this. And I have, I'm very

pleased that I have with me a number of experts on the tax side of this. I have with me,

Evigheert, director in our global tax team. Jonas van de Hecht, a transfer pricing partner

in our team, as well as Philippe van Pratt, senior manager in our global people

and organization team. I think we have all the experts we need to reflect a little bit on this

topic. And perhaps Jonas, I want to start with you. It would be good for the listeners that we

have a bit of an overview of what is ongoing and your perspective to that. Could you take us through that?

Yeah, definitely, Peter and welcome everyone. So just a bit of background on the relevance of the

topic. So maybe the BEPS project. Let's start with that one. It had an important impact on the

notion of substance in transfer pricing and also for international

tax. And I think most pronounced was the inclusion of the Dampi notion in the relation to intangibles

and the fact that risks and the returns associated with those risks should actually be allocated

to entities that exercise control and that have also financial capacity.

And so what we are witnessing today is that tax authorities around the world are starting to use these concepts

when reviewing international tax operations of multinationals,

but also that multinationals have dedicated their time to address the topic of substance,

considering the possibilities and constraints of the business, their business models, and also the evolution of those business models.

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