France introducing new transfer pricing provisions in the 2014 Finance Law
The 2014 Finance Law was adopted by the French Parliament on 19 December 2013 and was published in the French Official Journal on 30 December 2013. Background One of the core objectives of the 2014 Finance Law is to achieve structural balance with regards to public finances and to reinforce the fight against fraud and
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.
EC proposed amendment of the Parent-Subsidiary Directive
On 25 November 2013, the European Commission (hereafter: EC) proposed amendments to the Parent Subsidiary Directive (2011/96/EU; hereafter: PSD) in the context of the fight against tax fraud and evasion and aggressive tax planning/BEPS in the EU. The proposal seeks to tackle hybrid financial mismatches within the scope of application of the PSD and to introduce a general
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 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
