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 9: Risk and Capital

 Economy
Nov 152015
 

(First of two parts) Action 9 of the Base Erosion and Profit Shifting (BEPS) 2015 Final Reports deals with transferring risks among, and allocating excessive capital to, group members, as part of the consolidated Actions 8 -10 on aligning transfer pricing (TP) outcomes with value creation. Action 9, together with Action 10 (Other high-risk transactions), revises Chapter I, Section D (Guidance for applying the arm’s length principle) of the Organization for Economic Cooperation and Development (OECD) TP Guidelines.