miércoles, 31 de agosto de 2016

OECD releases discussion draft on revised guidance on profit splits

The OECD on July 4 released a Discussion Draft on Revised Guidance on Profit Splits. The discussion draft follows the work previously undertaken by the G20/OECD in relation to ensuring that transfer pricing outcomes are aligned with value creation (Actions 8-10 of the G20/OECD BEPS Action Plan). It does not reflect, at this stage, a consensus position of the governments involved, but is designed to provide substantive proposals for public review and comment.
The introduction to the discussion draft specifically indicates that insofar as the guidance differs from the guidance contained in the 2010 OECD Transfer Pricing Guidelines For Multinational Enterprises and Tax Administrations (“2010 OECD TPG”), it is not to be relied upon by taxpayers or tax administrations.
The discussion draft was eagerly anticipated following the issuance of a first non-consensus discussion draft on profit splits in December 2014, and the public consultation on the topic held at the OECD in March 2015. The BEPS final reports published October 5, 2015, did not incorporate any proposed consensus changes to Chapter II of the 2010 OECD TPG, providing instead that Working Party 6 (“WP6”) would reconvene in 2016 and 2017 to provide such consensus guidance. The discussion draft is the first step in WP6’s mandate regarding profit split for 2016-2017.

Source: Deloitte

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