Businesses have made their feelings clear about the OECD’s work on preventing treaty abuse, which is a sub-section of the organisation’s work on base erosion and profit shifting (BEPS).
The OECD’s transfer pricing baton has now been passed over to Andrew Hickman, formerly a transfer pricing partner at KPMG in the UK, who has spoken exclusively with TPWeek of his trepidation about taking on such a demanding role and what he hopes the next TP project will be.
As companies’ employees become more globally mobile, there is an increasing risk that a permanent establishment (PE) may occur unintentionally, leaving taxpayers at risk of taxable income liabilities.
Pascal Saint-Amans, director for the centre for tax policy and administration at the OECD, has responded to claims the OECD’s work on TP arbitration is moving too slowly.
Shell has won its most recent court battle with the Indian authorities in the Bombay High Court over its issuance of shares to a local entity, which the authorities have tried to claim additional income tax over.
