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Author: OECD
Publisher: OECD Publishing
Published: 2014-09-16
Total Pages: 134
ISBN-13: 9264219218
DOWNLOAD EBOOK →This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles.
Author: OECD
Publisher: OECD Publishing
Published: 2014-09-16
Total Pages: 48
ISBN-13: 9264219234
DOWNLOAD EBOOK →This document contains revised standards for transfer pricing documentation and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity.
Author: Oecd
Publisher: OCDE
Published: 2014-09-16
Total Pages: 130
ISBN-13: 9789264219205
DOWNLOAD EBOOK →This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles. The changes clarify the definition of intangibles and provide guidance for related parties; including transactions involving intangibles and the transfer pricing treatment of local market features and corporate synergies. Some transfer pricing issues relating to intangibles are closely related to other issues that are to be addressed during 2015, most notably in relation to the allocation of risk among MNE group members and recharacterisation of transactions. Because of those interactions some sections of this document are in intermediate form and will be finalised in 2015.
Author: OECD
Publisher: OECD Publishing
Published: 2017-07-10
Total Pages: 612
ISBN-13: 9264265120
DOWNLOAD EBOOK →This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.
Author: OECD
Publisher: OECD Publishing
Published: 2015-10-05
Total Pages: 190
ISBN-13: 9264241248
DOWNLOAD EBOOK →Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Actions 8-10.
Author: Michael Lang
Publisher: Linde Verlag GmbH
Published: 2019-04-11
Total Pages: 176
ISBN-13: 370941010X
DOWNLOAD EBOOK →Transfer pricing treatment of intangibles: Issues und developments In recent decades, intangibles have become one of the most relevant success factors for Multinational Enterprises (MNEs). Along with the increasing importance of intangibles for economies, their tax treatment has also been under scrutiny which includes inter alia respective transfer pricing issues. MNEs are seeking for the best ways to optimize their business arrangements with the related intangibles while, at the same time, getting the most tax-efficient treatment. On the other hand, tax authorities have become increasingly concerned with the ease that intangibles can be used in aggressive planning. These concerns have been noticed and addressed by the Organization for Economic Cooperation and Development which presented its main findings with respect to transfer pricing aspects of intangibles in Action 8 of the BEPS Project in 2015 and in the 2017 OECD Transfer Pricing Guidelines. This book is based on the outcomes of the presentations and discussions held during the WU Transfer Pricing Symposium, ‘Transfer Pricing and Intangibles: Current Developments, Relevant Issues and Possible Solutions’, that took place in October 2018 at the WU Vienna University of Economics and Business. The publication discusses the most important issues and recent developments related to transfer pricing treatment of intangibles. Starting with the definition of intangibles, it further deals with topics such as appropriate attribution of intangible-related profits, structuring of intangibles in MNEs, and proper valuation of intangibles. The authors, apart from providing a theoretical background to the discussed issues, also present case studies that show how certain issues can be approached in practice. Every chapter ends with a summary of the discussions held during the panels of the Transfer Pricing Symposium in which representatives of tax administrations, multinationals, and tax advisories presented their opinions on the issues at stake.
Author: OECD
Publisher: OECD Publishing
Published: 2024-02-19
Total Pages: 52
ISBN-13: 9264622837
DOWNLOAD EBOOK →As part of the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy agreed by the OECD/G20 Inclusive Framework on BEPS in October 2021, Amount B provides for a simplified and streamlined approach to the application of the arm’s length principle to in-country baseline marketing and distribution activities, with a particular focus on the needs of low-capacity countries. Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
Author: OECD
Publisher: OECD Publishing
Published: 2013-02-12
Total Pages: 91
ISBN-13: 9264192743
DOWNLOAD EBOOK →This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
Author: OECD
Publisher: OECD Publishing
Published: 2016-08-26
Total Pages: 24
ISBN-13: 9264263438
DOWNLOAD EBOOK →Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.
Author: OECD
Publisher: Org. for Economic Cooperation & Development
Published: 2015-10-19
Total Pages: 186
ISBN-13: 9789264241237
DOWNLOAD EBOOK →The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.
