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 ...

Public comments received on BEPS discussion draft on the transfer pricing aspects of financial transactions

On 3 July 2018, interested parties were invited to provide comments on a discussion draft on financial transactions, which deals with follow-up work in relation to Actions 8-10 (“Assure that transfer pricing outcomes are in line with value creation”) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the public comments received, according to a press release dated 14 September 2018 ...

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 ...

OECD releases BEPS discussion draft on the transfer pricing aspects of financial transactions

The OECD has released the BEPS discussion draft on the transfer pricing aspects of financial transactions: the Public Discussion Draft BEPS Actions 8-10 Financial Transactions. Public comments are invited on this discussion draft, which deals with follow-up work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value creation") of the BEPS Action Plan. This was announced by the OECD in a press release dated ...

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 releases 14 additional country profiles containing key aspects of transfer pricing legislation

The OECD has published new transfer pricing country profiles for Australia, China (People’s Republic of), Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden and Uruguay respectively, according to a press release on the website of the OECD.  These new profiles reflect the current transfer pricing legislation and practices of each country. The profiles of Belgium and the Russian Federation have also been updated. The country profiles are now ...

OECD releases additional guidance on the attribution of profits to a permanent establishment under BEPS Action 7

On 22 March 2018, the OECD released the report Additional Guidance on the Attribution of Profits to Permanent Establishments (BEPS Action 7), the OECD announced in a press release published on its website on 22 March 2018. In October 2015, as part of the final BEPS package, the OECD/G20 published the report on Preventing the Artificial Avoidance of Permanent Establishment Status. The Report recommended changes to the definition of permanent ...

European Commission proposes new measures for fair taxation of the digital economy

On 21 March 2018, the European Commission proposed new measures to ensure that digital business activities are taxed in a fair and growth-friendly way in the EU, “Fair taxation of the Digital Economy”, according to a press release dated 21 March 2018 on the website of the European Commission. The measures would make the EU a global leader in designing tax laws fit for the modern economy and the digital ...

Public comments received on the tax challenges of digitalisation

On 22 September 2017, interested parties were invited by the OECD to provide comments on the tax challenges of digitalisation. The OECD has published the public comments received in a document dated 25 October 2017: Tax Challenges of Digitalisation. Comments received on the Request for Input (Part I and Part II). The request for input outlined the background on the work regarding the tax challenges of digitalisation from the BEPS Action 1 ...

OECD invites public input on the tax challenges of digitalisation

The OECD is seeking public comments on key issues identified in a request for input related to the tax challenges raised by digitalisation and the potential options to address these challenges, according to an announcement of 22 September 2017 on the OECD’s website. The request for input outlines the background on the work regarding the tax challenges of digitalisation from the BEPS Action 1 report and invites comments on the impact of digitalisation on ...