21-June-2018
English
Today, the OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method under BEPS Action 10.
21-June-2018
English
The new guidance is aimed at reaching a common understanding and practice among tax administrations on how to apply adjustments resulting from the application of the approach to hard-to-value intangibles (HTVI). This guidance should improve consistency and reduce the risk of economic double taxation by providing the principles that should underlie the application of the HTVI approach.
21-June-2018
English
This report contains revised guidance on the profit split method, developed as part of Action 10 of the BEPS Action Plan. This guidance will be incorporated into the OECD Transfer Pricing Guidelines, replacing the previous text on the transactional profit split method in Chapter II.
9-May-2018
English
Public comments are invited on the future revision of Chapter IV, “Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes” of the Transfer Pricing Guidelines, and the future revision of Chapter VII, “Special Considerations for Intra-Group Services”, of the Transfer Pricing Guidelines.
9-April-2018
English
These country profiles focus on countries' domestic legislation regarding key transfer pricing principles, including the arm's length principle, transfer pricing methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, transfer pricing documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures.
9-April-2018
English
The OECD has published 14 new and 2 updated transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of participating countries. The country profiles, which are now available for 44 countries, contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves.
22-March-2018
English
The additional guidance resulting sets out high-level general principles, which countries agree are relevant and applicable in attributing profits to PEs in accordance with applicable treaty provisions. It also provides examples on the attribution of profits to certain types of PEs arising from the changes to the PE definition under BEPS Action 7.
22-March-2018
English
This report contains additional guidance on the attribution of profits to permanent establishments resulting from the changes in the Report on BEPS Action 7 to Article 5 of the OECD Model Tax Convention.
22-March-2018
English
Developed in the context of the OECD/G20 BEPS Project, the 15 BEPS actions equip governments with domestic and international instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created. Under the inclusive framework, over 100 countries and jurisdictions are now collaborating to implement the BEPS measures and tackle BEPS.
28-February-2018
English
It is my great pleasure to be here to launch the joint work programme with Brazil on transfer pricing, one of the core aspects of international tax policy.