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.
Martin Zetter (Macfarlanes) provides an overview of recent developments, with updates from Poland and India.
Organisation calls deliverables a ‘historical achievement on the long road to global tax justice’
The OECD has announced that it will release its first recommendations for a coordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 base erosion and profit shifting (BEPS) project on Tuesday 16 September 2014.
Martin Zetter (Macfarlanes) provides an update on the Amazon hearing in the US; plus transfer pricing news from India, Bolivia and Tanzania; and the OECD consultation on BEPS action 11