Comments on various OECD’s Discussion Drafts

By Robert Robillard - 9 September 2016

This blogpost originally appeared on rbrt.ca. Comments on numerous OECD's Discussion Drafts have recently been released: Comments on the BEPS discussion drafts on the Attribution of Profits to Permanent Establishments and the Revised Guidance on Profit Splits are available here: http://www.oecd.org/tax/public-comments-received-on-beps-discussion-drafts-on-attribution-of-profits-to-permanent-establishments-and-revised-guidance-on-profit-splits.htm Comments...

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BEPS Rules Now Officially Part of the OECD Transfer Pricing Guidelines

By Robert Robillard - 20 June 2016

This blogpost originally appeared on rbrt.ca. The OECD recently indicated: "On 23 May 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations ("Transfer Pricing Guidelines"), as set out in the 2015...

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USA Transfer Pricing Case Law: Medtronic v. Commissioner, T.C. Memo. 2016-11

By Robert Robillard - 16 June 2016

This blogpost originally appeared on rbrt.ca. In Medtronic v. Commissioner, T.C. Memo. 2016-112, available here, the Court summarizes the main issues as follow: "(1) whether income related to intercompany licenses for the intangible property required to manufacture medical device pulse generators...

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