OECD: Discussion Drafts on Attribution of Profits to PE and Revised Guidance on PSMPar Robert Robillard - 5 juillet 2016
This blogpost originally appeared on rbrt.ca.
Two discussion drafts were released on July 4, 2016 by the OECD:
- Attribution of Profits to Permanent Establishments, « which deals with work in relation to Action 7 (« Preventing the Artificial Avoidance of Permanent Establishment Status ») of the BEPS Action Plan. »
- Revised Guidance on Profit Splits, « which deals with work in relation to Actions 8-10 (« Assure that transfer pricing outcomes are in line with value creation ») of the BEPS Action Plan. »
Comments may be submitted to the OECD by 5 September, 2016 to TransferPricing@oecd.org in Word format.
The OECD also indicates:
« Comments in excess of ten pages should attach an executive summary limited to two pages. »
Duly noted… 🙂
The library on BEPS and Transfer Pricing is available here.
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