PwC BEPS webcast: A focus on hybrid mismatch arrangements (27 March)
Date: 27 March 2014 Time: 12:00 pm to 1:00 pm ET Duration: 60 minutes (including Q&A) Click here to register With the 19 March 2014 release of the discussion draft on Action 2 (Neutralise the effects of hybrid mismatch arrangements) of the Base Erosion and Profit Shifting (BEPS) Action Plan, we continue our series of
OECD – Paper on transfer pricing comparability data and developing countries released for comment
On March, 11th 2014, the OECD released a paper on transfer pricing comparability data and developing countries for comment. The paper sets out and briefly discusses four possible approaches to address the concerns over the lack of data on comparables expressed by developing countries. Background OECD and non-OECD countries frequently express concerns about the availability
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
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.
Momentum gathers behind the OECD Action Plan on Base Erosion and Profit Shifting (BEPS)
Download The BEPS Action Plan published by the OECD on 19 July 2013 represents the most ambitious and far-reaching attempt at reform of the global tax system in recent memory. This root and branch review of the global tax rules underpinning the world economy focuses on those cases where profits may be escaping taxation or
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
