Weekly transfer pricing roundup – 10 July

I feel like I am repeating myself, but yes another newsworthy week for transfer pricing. The OECD has released two long-awaited discussion drafts, namely, attribution of profits to PEs and revised guidance on profit splits. You can find both discussion drafts here. If you have any comments which you would like to put forward, let me know and I will collate them all to provide a response accordingly. On top of these two discussion drafts much more has happened.

Initiating your APA in Ireland (TP Week) 

Ireland has introduced a formal bilateral APA programme which came into effect on 1 July 2016. It may now be preferable to initiated your bilateral APA in Ireland…

OECD releases discussion drafts on attribution of MNE profits to permanent establishments and profit splits (MNE Tax)

The OECD today released two discussion drafts on international tax standards that deal with allocating multinational corporation profits between tax jurisdictions: guidance on the attribution of profits to permanent establishments (PEs) and proposed revisions to OECD transfer pricing guidelines on profit splits…

Multinational companies have increased their work on BEPS compliance, Thomson Reuters survey finds (Yahoo finance)

Two-thirds of corporate tax executives surveyed say their companies are proactively preparing for the onslaught of new tax regulations resulting from the BEPS Action Plan.

That’s a 22% increase in the past year. In Thomson Reuters 2015 BEPS Readiness Survey, 54% of respondents said they were actively preparing for the new reporting requirements. This year, it`s 66%…

OECD proposes conforming amendments to transfer pricing guidelines on business restructuring (MNE Tax)

The OECD on July 4 published proposed amendments to Chapter IX of the transfer pricing guidelines dealing with business restructuring to conform the guidance to recent changes made to other chapters on account of the final OECD/G20 base erosion profit shifting (BEPS) reports. Significant changes were made to Chapter 1 of the guidelines concerning delineating transaction and allocating risk.

The OECD is not open to any discussions about the concepts in the draft; it just seeks feedback on whether the conforming changes address all inconsistencies between Chapter IX and the revised transfer pricing guidelines and whether the proposed changes remove all duplication in the chapters…

Transfer pricing deals to get special scrutiny after inversions (BNA)

Transfer pricing deals are among post-inversion transactions IRS agents should be closely scrutinizing, the agency said in a newly posted audit guide.

At a time when the agency is in the midst of a crackdown on inversions, the new international practice unit calls for agents to put both these transactions and the tax planning that happens afterwards under the microscope…

US tax authorities seek to challenge Facebook over transfer pricing (CCH Daily)

The US Internal Revenue Service (IRS) is seeking information from Facebook about the transfer of various rights associated with its global business to a holding company in Ireland, over concerns that these may have not been valued correctly for accounting purposes…

 

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