OECD publishes long-awaited public discussion draft on the transfer pricing aspects of financial transactions
On 3 May 2018, the OECD published a long-awaited public discussion draft on the transfer pricing aspects of financial transactions. With this publication, the OECD has reached another important milestone in the BEPS saga. As all groups have such transactions, the importance of the discussion draft cannot be underestimated. The discussion draft has been developed
OECD releases discussion draft on branch mismatch structures
On 22 August 2016, the OECD published, for discussion, recommendations for domestic laws that would neutralise the effect of payments involving certain branch mismatch arrangements. This expansion of the final Base Erosion and Profit Shifting (BEPS) Action 2 paper, Neutralising the Effects of Hybrid Mismatch Arrangements, issued on 5 October 2015, adds even more complexity
Revised OECD Discussion Draft on Treaty Abuse published
On Friday, 22 May 2015, the OECD issued a Revised Discussion Draft on BEPS Action 6: Prevention of Treaty Abuse (the RDD). The RDD includes a simplified Limitation on Benefits (LOB) Article for inclusion in the OECD Model Income Tax Convention and provides ‘conclusions and proposals’ on 20 targeted issues. Most of the proposals are
Revised OECD Discussion Draft on permanent establishments – PwC Newsflash published
As mentioned in the news alert published on 18 May 2015, the OECD issued a revised discussion draft on preventing the artificial avoidance of permanent establishment (‘PE’) status under Action 7 of the BEPS Action Plan. The earlier OECD proposals, which set out alternative approaches to a number of significant PE issues, have been replaced by
Revised OECD Discussion Draft on permanent establishments published
On 15 May 2015, the OECD issued a revised discussion draft on preventing the artificial avoidance of permanent establishment (‘PE’) status under Action 7 of the BEPS action plan. The proposals in this revised discussion draft (which the OECD calls the ‘new discussion draft’ or ‘second discussion draft’) were all included among the options that appeared
Revised OECD BEPS timetable
The OECD has published a revised OECD timetable for stakeholders’ input, with the dates when new discussion drafts will be published and public consultations will be held in relation to the 2015 Base Erosion and Profit Shifting (BEPS) outputs. The revised OECD timetable can be consulted here. During March and April 2015, the OECD released
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