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.
Chris Morgan (KPMG) provides an update on recent international developments, including: the CJEU’s release of the AG opinion on the UK rules on cross-border group relief following Marks & Spencer; EU finance ministers’ agreement on an extended information exchange mechanism; Ireland’s 2015 Budget announcement on the ‘double Irish’ tax structure; corporation tax reform III in Switzerland; and the Centrica case in India.
Two of the BEPS deliverables that the OECD issued on 16 September indicate transfer pricing changes. These relate to intangibles and documentation. Martin Zetter (Macfarlanes) takes a look.
Richard Collier and Philip Greenfield (PwC) examine the OECD’s first set of recommendations for tackling base erosion and profit shifting (BEPS) - finding few surprises, but no let up.