It is clear that the government feels the need to ‘do something’. However, it is much less clear that the diverted profits tax proposals is the best thing to do, as Heather Self (Pinsent Masons) explains.
Traditional treaty principles that allocate taxing rights between residence and source states, which have long formed the cornerstone of international tax consensus, are undergoing rapid re-evaluation, writes Jonathan Schwarz (Temple Tax Chambers)
How does the ‘nexus’ approach, proposed by the UK and Germany for future IP regimes, differ from the ‘transfer pricing’ approach of the UK patent box, asks Peter Denison-Pender (MMP Tax Ltd)
The OECD invites comments by 9 January 2015 on a discussion draft dealing with follow-up work mandated by the report on action 6 of the BEPS project (preventing treaty abuse) published in September 2014.
Martin Zetter (Macfarlanes) provides this month’s international transfer pricing news, with updates from Hungary, Russia, Slovak Republic and Morocco.
What the OECD is doing to deepen its engagement with developing countries. Renáta Ardous (Mazars) reports
The OECD recently released its discussion draft on the reform of the permanent establishment (PE) rules. Richard Collier (PwC) examines the proposals
As part of the G20/OECD’s work on BEPS in relation to action 10 and transfer pricing of high risk transactions, the discussion draft on the transfer pricing of low value-adding intra-group services has been published. Alison Lobb (Deloitte) reviews the detail
To anyone involved in the infrastructure sector, action point four of the OECD’s BEPS project – to ‘limit base erosion via interest deductions and other financial payments’ – is bad news for highly geared projects, writes Eloise Walker (Pinsent Masons)
The OECD has released two discussion drafts for public consultation, with comments invited until January.