Besluit inzake verrekenprijzen, de toepassing van het arm’s-lengthbeginsel en de Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Nederland)
Op 1 juli 2022 is het Besluit van 14 juni 2022, nr. 2022-0000139020, van de staatssecretaris van Financiën inzake verrekenprijzen, de toepassing van het arm’s-lengthbeginsel en de Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OESO-richtlijnen) gepubliceerd in de Staatscourant van het Koninkrijk der Nederlanden, jaargang 2022, nr. 16685 (Stcrt. 2022, 16685). In dit besluit wordt nadere invulling gegeven aan de toepassing van het zogenoemde arm’s-lengthbeginsel. Het arm’s-lengthbeginsel is in ...
OECD releases latest edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
The OECD has released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. This has been announced on 20 January 2022 with a news release on the website of the OECD. Furthermore form the news release: The OECD Transfer Pricing Guidelines provide guidance on the application of the "arm’s length principle", which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between ...
OECD publishes information on the state of implementation of the hard-to-value intangibles approach by members of the Inclusive Framework on BEPS
The OECD has published jurisdiction-specific information on the implementation of the hard-to-value intangibles ("HTVI") approach. To date, 40 jurisdictions have provided information on whether their domestic legal system provides for transfer pricing rules aimed at transactions involving HTVI. This has been announced by the OECD in a press release dated 16 December 2020. Furthermore from the press release: The publication of this information is part of the monitoring process of the implementation ...
OECD releases Transfer Pricing Guidance on Financial Transactions
On 11 February 2020, the OECD released the report Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10. This was announced in a press release published on the website of the OECD. In October 2015, as part of the final BEPS package, the OECD/G20 published the reports on Action 4 (Limiting Base Erosion Involving Interest Deductions And Other Financial Payments) and Actions 8-10 (Aligning Transfer Pricing Outcomes with ...
OECD expands transfer pricing country profiles to cover 55 countries
The OECD has released new transfer pricing country profiles for Chile, Finland and Italy, bringing the total number of countries covered to 55. In addition, the OECD has updated the information contained in the country profiles for Colombia and Israel, according to a press release dated 18 June 2019 on the website of the OECD. These country profiles reflect the current state of legislation and practice in each country regarding the application ...
OECD releases seven new transfer pricing country profiles and an update of a previously-released profile
The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa and Turkey. In addition, it has also updated the information contained in Singapore’s profile. The country profiles are now available for 52 countries. This was announced in a press release of 7 September 2018 as published on the website of the OECD. The OECD continues to publish and update the transfer pricing ...
Public comments received on the scope of the future revisions of Chapter IV (Administrative Approaches) and Chapter VII (Intra-group services) of the Transfer Pricing Guidelines
On 9 May 2018, interested parties were invited to provide comments on the scope of the future revisions of Chapter IV (Administrative Approaches) and Chapter VII (Intra-group services) of the Transfer Pricing Guidelines. The OECD has now published the public comments received. In a press release dated 28 June 2018 the OECD expresses that it is grateful to the commentators for their input. Sofar an extract from the press release referred to ...
OECD releases new guidance on the application of the approach to hard-to-value intangibles and the transactional profit split method under BEPS Actions 8-10
On 21 June 2018, the OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10. From the press release dated 21 June 2018 as published on the website of the OECD: In October 2015, as part of the final BEPS package, the OECD/G20 published ...
OECD invites public comments on the scope of the future revision of Chapter IV (administrative approaches) and Chapter VII (intra-group services) of the Transfer Pricing Guidelines
The OECD is considering starting two new projects to revise the guidance in Chapter IV (administrative approaches) and Chapter VII (intra-group services) of the Transfer Pricing Guidelines, according to an announcement dated 9 May 2018 on the website of the OECD. Public comments are invited on: the future revision of Chapter IV, “Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes” of the Transfer Pricing Guidelines, and the future revision of Chapter VII, ...
OECD updates transfer pricing country profiles reflecting transfer pricing legislation and practices
The OECD has published updated versions of transfer pricing country profiles (TPCP), reflecting the current transfer pricing legislation and practices of 31 participating countries. The country profiles contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves. For more information, click here to go to the announcement referred to above dated 6 November 2017 on the website of the OECD. CFN-artikelnr. 20171110-9 BRONDOCUMENT BRON: www.oecd.org Land/gebiedsdeel: ...
OECD releases latest updates to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
On 10 July 2017 the OECD released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises. The 2017 edition of the Transfer Pricing Guidelines mainly reflects a consolidation of the ...
Public comments received on the BEPS discussion draft on the Implementation Guidance to Hard-to-Value Intangibles
On 5 July 2017 the OECD published the public comments received on a discussion draft that provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines. On 23 May 2017, interested parties were invited to provide comments on said discussion draft. CFN reported on said invitation in its edition of 26 May 2017, nr. 2017/17. CFN-artikelnr. 20170707-8 BRONDOCUMENT ...
OECD releases a discussion draft on the implementation guidance on hard-to-value intangibles
On 23 May 2017 the OECD released a discussion draft on the implementation guidance on hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines and invites public comments. For more information, click here. CFN-artikelnr. 20170526-9 BRON: www.oecd.org Land/gebiedsdeel: OECD Betreft: Internationaal belastingrecht, implementation guidance, discussion draft, hard-to-value-intangibles, transfer pricing, TP, Transfer Pricing Guidelines, BEPS, Base Erosion and Profit Shifting, BEPS Action 8 Regeling: OECD discussion draft dated ...