OECD White Paper on Transfer Pricing Documentation proposes a coordinated approach to simplification based on a two-tier structure
Download > The OECD’s White Paper on Transfer Pricing Documentation takes stock of the existing approaches to harmonising transfer pricing documentation, but goes considerably further by proposing a coordinated approach to documentation based on a two-tier structure. Building on the EU’s TPD, the paper advocates the creation of a global masterfile giving important information about
Belgium: Shifting gears towards transfer pricing audits
In brief In the last few days in Belgium, PwC has observed a large number of transfer pricing audits being initiated. The Belgian tax administration appears to be shifting gears on the transfer pricing front in order to raise revenues and prevent erosion of the tax base. Due to the lack of resources within the
Belgium: Shifting gears towards transfer pricing audits
Download The Belgian tax administration has made additional resources available to increase the number of intercompany transactions audits. And we’ve already noticed that there’s been a significant increase in the number of audits taking place – an estimated 150 audits has been initiated so far. It is not clear yet which types of companies are
Highlights and initial comments from the Public Consultation days on the OECD Intangibles Draft
Download 120 business commentators from at least 70 companies (including corporations, consulting firms, law firms and industry organisations) convened in Paris from 12 to 14 November 2012 to discuss three important OECD Discussion Draft topics, including : The Intangibles Draft Safe Harbours Timing Issues PwC was present on this the fourth public consultation on the
The Discussion Draft on Chapter VI of the OECD Guidelines on ‘Intangibles‘: PwC’s observations
Download The highly anticipated Discussion Draft of Chapter VI of the OECD’s Transfer Pricing Guidelines and Related Provisions (the Intangibles chapter), clearly shows that the OECD has made significant progress since they kicked off the project in November 2010. Some of the highlights we discuss are the definitional aspects of intangibles, ownership and entitlement to
