viernes, 7 de julio de 2017

OECD releases BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits

On June 22, 2017, the OECD released two public discussion drafts providing further guidance on the Final Reports on Base Erosion and Profit Shifting (BEPS) published in October 2015, both replacing previous drafts released on July 4, 2016 which were subject to public consultation on October 11-12, 2016.

The first discussion draft provides practical guidance on how to attribute profits to permanent establishments (PE) following the finalisation of the BEPS Action 7 report, while re-emphasising that the principles of the Authorised OECD Approach (AOA) to attributing profits to PE remain unchanged.

The second discussion draft provides revised guidance on profit split methodologies (PSM). This discussion draft links with BEPS Action 10 and serves to clarify and strengthen the guidance in Chapter II of the OECD Transfer Pricing Guidelines (TPG).

Comments on both discussion drafts are invited by September 15, 2017, with public consultations planned in November 2017.

Source & more info: PwC

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