OECD: Discussion Drafts on Attribution of Profits to PE and Revised Guidance on PSMBy 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.
The convergence of RBRT’s tax, accounting and economics expertise makes a difference. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. or the author are not responsible or liable for any error, omission or inaccuracy in such information. The opinions expressed in this blogpost are those of the author. Readers should seek advice and counsel from RBRT Inc. as required.