Global advisory firm Duff & Phelps has hired Ted Keen, who will serve as the European leader for the firm’s transfer pricing practice from London.
On June 21, 2018, the OECD released two reports setting out key guidance on the application of the approach to hard-to-value intangibles, and on the application of the transactional profit split method, as part of its work on base erosion and profit shifting (BEPS) project.
The Swiss Federal Tax Administration (FTA) will exchange this month 109 country-by-country (CbC) reports of multinational enterprises’ (MNEs) with 35 foreign tax jurisdictions.
The United Nations has published the 2017 update to the UN Model Tax Convention, which incorporates changes agreed as part of the base erosion and profit shifting (BEPS) project.
60 out of 90 countries have introduced tax legislation to implement country-by-country (CbC) reporting obligation for multinational enterprises (MNEs), in line with Action 13 of the base erosion and profit shifting (BEPS) project, according to a May 24 OECD report.
The transfer pricing of intangible properties has always been a significant issue for multinational enterprises (MNEs). The excellent idea devoted to this matter with the current drive of the OECD to counter tax base erosion is dim long over-due. Indeed, the case with transfer pricing is technically considered a neutral concept but erroneously taken as an offensive action of MNEs that permits them to transfer profits generated by intangibles to so-called tax havens. Although, the arm’s length principle enshrine in the OECD Model has been misidentified as the primary instrument to tackle such abusive behavior of MNEs.
The UAE has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS).
The Inclusive Framework on BEPS allows interested countries and jurisdictions to work with the OECD and Group of Twenty nations on monitoring the implementation of the BEPS proposals.
When states attain membership of the European Union (EU), the governments are in charge of enacting and implementing their local direct taxation policy. The tax framework of the member-states shall not contravene or interfere the laid down policies and directives of the EU institutions; therefore, the sovereignty of member states is extremely safeguarded. Although the EU faces difficulties to come up with results that would be generally accepted by all member states, it has taken every step to integrate all Member States’ corporate direct taxation systems since the 1950s.
As an active participant in the OECD’s base erosion and profit shifting (BEPS) project, India has implemented nearly all the BEPS recommendations and has taken several steps to amend the country’s domestic tax laws appropriately. The Indian Finance Act, 2016 implemented BEPS Action Item 13 by introducing a three-tiered transfer pricing documentation structure and made it effective from the 2016-17 financial year.
The Indian tax authority has published for public comments a draft Notification, which will implement the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project.