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
PwC’s comments on the OECD White Paper on Transfer Pricing Documentation
In July 2013, the OECD released a White Paper on Transfer Pricing Documentation. This is a hot topic for policy makers since local pricing documentation requirements are rapidly growing, making transfer pricing increasingly complicated. The OECD invited the business community to provide input on their white paper and PwC was happy to oblige, providing detailed
PwC’s comments on the OECD White Paper on Transfer Pricing Documentation
Download In July 2013, the OECD released a White Paper on Transfer Pricing Documentation. This is a hot topic for policy makers since local pricing documentation requirements are rapidly growing, making transfer pricing increasingly complicated. The OECD invited the business community to provide input on their white p aper and PwC was happy to oblige,
