How BEPS Action Plans are changing transfer pricing

 Economy
Apr 022017
 

Ernst & Young (EY) recently conducted a Transfer Pricing Survey to determine how companies are addressing the Action Plans issued by the Organisation for Economic Co-operation and Development (OECD) under the Base Erosion and Profit Shifting (BEPS) project. The survey involved respondents in 36 jurisdictions and across 17 industries.
As a background, the BEPS project was initiated at the request of G20 countries to address issues arising from the use of old tax frameworks that do not match current practice of doing business across borders.

BEPS discussion draft: revised guidance on profit splits

 Economy
Sep 112016
 

In 2015, the Organization for Economic Co-operation and Development (OECD) released its final reports on base erosion and profit shifting (BEPS). The reports addressed 15 focus areas, including “Aligning Transfer Pricing Outcome with Value Creation, Actions 8-10 — 2015 Final Reports,” issued on Oct. 5, 2015. BEPS Action Plans 8-10 provided discussions regarding, among others, the “Guidance on Applying Arm’s Length Principle” and “Scope of Work for Guidance on the Transactional Profit Split Method.” The discussions mentioned additional work to be conducted by the OECD to produce new guidance on the application of the transactional profit split method.

BEPS action plan 14: Making dispute resolution mechanisms more effective

 Economy
Jan 312016
 

(First of two parts) In our previous columns, we discussed the final reports of the Organisation for Economic Co-operation and Development (OECD) on the different action plans to address Base Erosion and Profit Shifting (BEPS). We will now focus on Action 14, which reflects the commitment of participating countries to implement substantial changes in their approach to dispute resolution.