Upcoming Global OECD BEPS webcasts
In the framework of the upcoming G20 Finance Ministers meeting to be held in Cairns, Australia on 20-21 September 2014, there are two global OECD BEPS webcasts scheduled this month for you in order to guide you through and anticipate on any potential impact on your businesses: BEPS: Global alignment vs national interest?: This first is a live
OECD Publishes 2014 Update to Model Tax Convention
The OECD Council approved the 2014 Update to the OECD Model Tax Convention (the 2014 Update) on 15 July 2014. The 2014 Update was already approved by the Committee on Fiscal Affairs on 26 June 2014. The 2014 Update can be found here. The 2014 Update mainly reflects the work that was carried out by the OECD
Danish National Tax Tribunal publishes its first decision regarding a cash pool arrangement
In early 2014,the National Tax Tribunal (Landsskatteretten) published its first transfer pricing decision regarding a cash pool arrangement. The decision concerns the determination of intercompany interest rates on deposits and borrowings in the cash pool. The National Tax Tribunal ruled that the Danish tax authorities were allowed to disregard the transfer pricing applied by the
Formal EU State Aid investigation into certain tax rulings
On June 11, 2014, the European Commission opened a formal State Aid investigation procedure into the transfer pricing arrangements and corporate taxation of certain companies in Ireland, the Netherlands and Luxembourg. See this link for more information. Wider inquiry into tax rulings In parallel to these three formal investigations, the Commission will continue its wider inquiry
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
The OECD’s public consultation on transfer pricing documentation and country-by-country reporting on 19 May
The OECD will hold a public consultation on the discussion draft on transfer pricing documentation and country-by-country reporting on 19 May 2014 at the OECD Conference Centre in Paris, France. The public consultation will be broadcast live on the Internet and can be accessed on line. No advance registration will be required for Internet access. Persons wishing
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
BEPS Webcast – A focus on the digital economy, 17 April 2014
The OECD recently released its discussion draft focused on the digital economy as part of the Base Erosion and Profit Shifting (BEPS) Action Plan. In response to this draft, we will hold another webcast in our series of BEPS related webcasts. Please join us on 17 April where we will review the latest discussion draft
