Despite the OECD’s Base Erosion and Profit Shifting (BEPS) project being much broader than the intangibles project in terms of its impact on corporate tax, the time frame for the BEPS is much shorter and there is more pressure for the working group to provide guidance.
Jitendra Grover, global head of tax for Aricent Group, a global innovation and technology services company, warns that if a person is providing services for an entity in one country (home country) and has spent a considerable length of time in another country (most tax treaties provide for 90 days to 180 days) they would constitute a permanent establishment (PE) of the home country entity.
Germany’s Federal Ministry of Finance has published draft legislative regulations for determining profits of permanent establishments (PE) using the arm’s-length standard. But advisers are concerned the legislation will increase transfer pricing risks.
The OECD's Action Plan for tackling base erosion and profit shifting (BEPS) was unveiled on July 19 at the G20 meeting of finance ministers in Moscow. The plan discusses a timeframe of between 12 and 24 months for implementing action and outlines how the OECD will work with national states to improve the overall tax take and clamp down on tax arbitrage by addressing perceived flaws in international rules. The plan specifically references transfer pricing and Sophie Ashley discusses its impact on global principles and how taxpayers can expect them to change.
The OECD’s Action Plan for tackling base erosion and profit shifting (BEPS) was unveiled on July 19 at the G20 meeting of finance ministers in Moscow. The plan discusses a timeframe of between 12 and 24 months for implementing action and outlines how the OECD will work with national states to improve the overall tax take and clamp down on tax arbitrage by addressing perceived flaws in international rules.
Renowned tax and transfer pricing professionals from industry, including Caterpillar, Nissan Europe, The Dow Chemical Company, Hewlett-Packard, Dell, Alstom, Lexmark International and Brown-Forman, along with officials from the OECD and the IMF, have agreed to share their industry experiences of some of the most difficult and contentious issues in transfer pricing.
