OECD publishes (long awaited) additional guidance on hard-to-value intangibles and profit split methods
In view of landing on the Transfer Pricing track in its work to curb Base Erosion and Profit Shifting (BEPS Actions 8-10) the OECD published two new reports on 21 June 2018: Guidance for tax administrations on the application of the approach to hard-to-value intangibles; and Revised guidance on the application of the profit split
OECD Public Consultation on BEPS Actions 8 through 10 reveals planned revisions to transfer pricing drafts
During the July 6-7, 2015 public consultation on BEPS Actions 8 through 10, the OECD Working Party 6 announced planned revisions to its proposed changes to the Transfer Pricing Guidelines, including its December 2015 papers on Risk, Recharacterisation and Special Measures and Use of Profit Split Methods and its 2014 draft on Intangibles. The OECD
OECD publishes PE discussion draft (artificial avoidance)
The OECD has published its discussion draft on the Preventing of Artificial Avoidance of permanent establishment (PE) Status. This publication follows the BEPS (Base Erosion and Profit Shifting) timeline. A fundamental change to the existing PE rules, with a potentially wide impact on many structures currently in use by MNCs, are proposed in the OECD
OECD publishes comments on TP Comparability Data and Developing Countries paper
On 11 March 2014, the OECD invited comments from interested parties on the paper on Transfer Pricing Comparability Data and Developing Countries. This paper discusses four possible approaches to addressing the concerns expressed by developing countries over the lack of data on comparables (expanding access to data sources for comparables, more effective use of data sources
OECD guidance on Transfer Pricing Aspects of Intangibles: Revised Chapters I, II and VI of the OECD Transfer Pricing Guidelines
On 16 September 2014, the OECD published its final and interim revisions in relation to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. These revisions have been developed in connection with Action 8 of the Action Plan on Base Erosion and Profit Shifting that is focused
BEPS: OECD is gearing up towards the September deadlines
The OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) was published in July 2013 with a view to addressing perceived flaws in international tax rules. The 40-page Action Plan, which was negotiated and drafted with the active participation of the OECD member states, contains 15 separate action points or work streams, some of which are
The EU Joint Transfer Pricing Forum published the transfer pricing profiles of EU Member States.
The EU Joint Transfer Pricing Forum has published various transfer pricing profiles of EU Member States on its website. These profiles contain information for the EU Member States on the domestic transfer pricing framework and regulations, transfer pricing documentation requirements, information on dispute resolution, competent authorities’ contact details and other transfer pricing related topics. The
PwC comments on the Discussion Draft on Transfer Pricing Comparability Data and Developing Countries
PwC has provided the OECD with its comments on the ‘discussion draft on transfer pricing comparability data and developing countries’ on 11 April 2014. PwC agrees with the OECD in that comparability is at the heart of transfer pricing, and that the application of the arm’s length principle often relies on a comparison of the prices charged
