PwC’s comments on OECD TP documentation draft and CbC reporting
PwC has released its response to the OECD’s Discussion Draft launched in the context of BEPS Action point 13. Click here to read PwC’s Comments The Discussion Draft was issued on January 30 and comments were due yesterday. A public OECD consultation meeting will follow on May 19. Needless to say that we are monitoring
EU JTPF agrees on common criteria for acceptance of compensating adjustments
Download In January 2014, the EU Joint Transfer Pricing Forum (‘JTPF’) finalised its Report on Compensating Adjustments (‘the Report’). The document offers practical solutions to both EU tax administrations and taxpayers on how to deal with the issue of compensating adjustments. 1. Background The Report is the response of the JTPF on the level of
OECD draft on transfer pricing documentation and country-by-country reporting
Download Webcast Multinational enterprises (MNEs) will face materially increased compliance burdens as a result of the hotly debated proposals to report to tax administrations, on a country-by-country basis, extensive details of their income, taxes, and business activities. Further, extensive changes to the current requirements for transfer pricing documentation reporting will also add to this burden.
Momentum gathers behind the OECD Action Plan on Base Erosion and Profit Shifting (BEPS)
Download The BEPS Action Plan published by the OECD on 19 July 2013 represents the most ambitious and far-reaching attempt at reform of the global tax system in recent memory. This root and branch review of the global tax rules underpinning the world economy focuses on those cases where profits may be escaping taxation or
PwC’s comments on the Revised Discussion Draft on Transfer Pricing Aspects of Intangibles
Download In July 2013, the OECD released its Revised Discussion Draft on the Transfer Pricing Aspects of Intangibles. PwC immediately informed its network of what had changed compared to the prior Discussion Draft. Now we are also providing you with the more detailed comments we sent the OECD regarding their Revised Discussion Draft. The following
OECD project on intangibles: Revised Discussion Draft released
Download The OECD’s Revised Discussion Draft contains several important changes. These were based on the comments received on the prior Discussion Draft. The majority of the document provides additional guidance on how to correctly allocate ‘return related to an intangible’ (also described as: ‘intangible related return’). The Revised Discussion Draft states that although contractual relationships
OECD’s Action Plan published on Base Erosion and Profit Shifting (BEPS)
Download The publication of the Action Plan and the items listed therein represent a milestone in the ongoing debate on how policy makers and governments will deal with base erosion and profit shifting in the near to long-term future. The desired outcome of the OECD’s BEPS Project is to provide balanced and effective strategies for
OECD project on intangibles: Revised Discussion Draft released
The OECD’s Revised Discussion Draft contains several important changes. These were based on the comments received on the prior Discussion Draft. The majority of the document provides additional guidance on how to correctly allocate ‘return related to an intangible’ (also described as: ‘intangible related return’). The Revised Discussion Draft states that although contractual relationships between
