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Author: Publisher: ISBN: Category : Languages : en Pages :
Book Description
QUESTIONS: 1. Please indicate if the profit split method is provided for in your country legislation and, if so whether your country legislation provides guidance on its application. Please elaborate on the domestic guidance on this issue which goes beyond the guidance contained in Chapter II of the OECD Transfer Pricing Guidelines. In case your country legislation does not provide for the use of the profit split method, please explain whether it is actually used in practice by taxpayers and its acceptability by tax administrations. 2. Based on your practical experience, please elaborate in what scenarios/structures/circumstances is the profit split method found to be the most appropriate method. Please also provide information on which are the instances in which profit split method is most commonly used (e.g. application by taxpayer, audit, APA, dispute resolution). 3. Based on your practical experience, what information can be useful in determining the arm's length allocation among the entities of a group of the (residual) profit under the profit split method (e.g. information prepared for tax and non-tax purposes; information from third party cooperative arrangement, such as joint ventures), and what are the practical obstacles to obtain and/or use such information in the transfer pricing analysis. 4. Based on your practical experience, please indicate which are the key limitations and/or practical difficulties encountered in applying the profit split method (e.g. new business models/operating structures, access to information, computation of profits, identification of appropriate allocation keys), and how could these be overcome or minimized.
Author: Publisher: ISBN: Category : Languages : en Pages :
Book Description
QUESTIONS: 1. Please indicate if the profit split method is provided for in your country legislation and, if so whether your country legislation provides guidance on its application. Please elaborate on the domestic guidance on this issue which goes beyond the guidance contained in Chapter II of the OECD Transfer Pricing Guidelines. In case your country legislation does not provide for the use of the profit split method, please explain whether it is actually used in practice by taxpayers and its acceptability by tax administrations. 2. Based on your practical experience, please elaborate in what scenarios/structures/circumstances is the profit split method found to be the most appropriate method. Please also provide information on which are the instances in which profit split method is most commonly used (e.g. application by taxpayer, audit, APA, dispute resolution). 3. Based on your practical experience, what information can be useful in determining the arm's length allocation among the entities of a group of the (residual) profit under the profit split method (e.g. information prepared for tax and non-tax purposes; information from third party cooperative arrangement, such as joint ventures), and what are the practical obstacles to obtain and/or use such information in the transfer pricing analysis. 4. Based on your practical experience, please indicate which are the key limitations and/or practical difficulties encountered in applying the profit split method (e.g. new business models/operating structures, access to information, computation of profits, identification of appropriate allocation keys), and how could these be overcome or minimized.
Author: S.K. Bilaney Publisher: ISBN: Category : Languages : en Pages :
Book Description
This article provides a critical overview of the OECD's revised draft guidance of 2017 on the profit split method. In this context, the author suggests important ways in which to make the method more practical in its application.
Author: Gabriella Cappelleri Publisher: Kluwer Law International B.V. ISBN: 9403524316 Category : Law Languages : en Pages : 341
Book Description
The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods, the profit split method (PSM) is under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In this thorough and detailed commentary – the first book to analyse this increasingly adopted transfer pricing method – notable scholars and practitioners working in the international tax community express their views on the method, answering some unresolved questions and highlighting issues that are still open and pending, especially in light of the digitalization of the economy. Crucial issues covered by the contributors include the following: choice of the appropriate splitting factors, their relative weights, and valuation of the contributions; uncertainties and outcomes potentially not aligned with the arm’s-length standard; possible role of assessments made by the European Commission on State aid; nexus with the work done by the EU Joint Transfer Pricing Forum; impact of profit split on indirect taxes (VAT/customs tax/excise tax); and application to digital business models and, in general, to the digitalized economy. Moreover, relevant experience of applying this method in France, Germany, Italy, Spain, Switzerland, the United Kingdom, and the United States is provided. A concluding chapter also deals with selected industry experiences. Due to a high level of uncertainty in alignment with international guidance in the application of the PSM – and to the underdeveloped nature of current literature on the subject – there is a need for this book because both tax administrations and taxpayers, going forward, will apply the PSM extensively. The book is highly relevant for policymakers, tax administrations, practitioners and academics engaged in the areas of international taxation, transfer pricing and tax policy.
Author: S. Zucchetti Publisher: ISBN: Category : Languages : en Pages :
Book Description
The OECD, in response to the mandate under the BEPS Project of developing rules in order to ensure allocation of profits in line with the actual value creation, recently revised the guidelines provided for the application of the transactional profit split method. This article analyses the new provisions contained in the Revised Guidance 2018 and discusses practical approaches which can be taken in order to apply the method in a reliable manner, and to some extent elucidates the OECD's thoughts on some particular issues.
Author: S.K. Bilaney Publisher: ISBN: Category : Languages : en Pages :
Book Description
This article provides a critical overview of the OECD's revised draft guidance on the transfer pricing profit split method and makes important suggestions as to how to make the method more practical in its application.
Author: C. Bagran Ilhan Publisher: ISBN: Category : Languages : en Pages :
Book Description
This article provides an introduction to the profit split method (PSM), giving a quick look into its evolution throughout time and explaining how it shall be identified and applied as the most appropriate transfer pricing method, while demystifying the terms "value creation" and "value chain analysis" (VCA) and explaining why they were introduced by the OECD in the Action Plan on Base Erosion and Profit Shifting (BEPS) Actions. The article elaborates on what a VCA should consider, how it should be conducted and what should be the outcome, and addresses the practical aspects of the use of the PSM in a VCA, based on a numerical example in the light of the OECD's recommendations in, inter alia, the OECD Model Tax Convention, the OECD Transfer Pricing Guidelines, the BEPS Actions, discussion drafts and public consultations on the application of the PSM.
Author: Robert T. Cole Publisher: Aspen Publishers ISBN: Category : Business & Economics Languages : en Pages : 1302
Book Description
Practical Guide to U.S. Transfer Pricing is a total approach to U.S. transfer pricing For The complex global marketplace. No book on the market today offers you a more thorough approach to transfer pricing rules that Practical Guide to U.S. Transfer Pricing. The tremendous increase in international trade among the nations of the world has made transfer pricing the most important international tax issues for governments. Thus, it is a major problem for major multinational corporations, which are subject to detriments from transfer pricing rules and adjustments, especially double taxation, penalties, And The cost of compliance. Packed with ready-to-use guidelines, detailed examples, and useful tips, Practical Guide to U.S. Transfer Pricing has been specifically designed to help you make today's transfer pricing rules work for your corporation. The book brings together For The first time, a wealth of features that will empower you to deal quickly and efficiently with all transfer pricing issues and problems. You will find: Unsurpassed coverage of U.S. transfer pricing substantive rules Incisive comparisons of the U.S. rules To The international accepted OECD Transfer Pricing Guidelines Information on both special and traditional procedures for transfer pricing cases Comprehensive explanations of all major transfer pricing methods, such as the Comparable Uncontrolled Price Method, Cost Plus Method, Comparable Profits Methods, and Profit Split Method Criteria for choosing the best transfer pricing method Ideas on how to cope with the U.S. rules in light of foreign requirements A checklist that multinationals can use in developing an international strategy for transfer pricing compliance A full description of the proposed method of global trading of financial products.
Author: Vikram Chand Publisher: ISBN: Category : Languages : en Pages : 7
Book Description
In this coauthored publication, the authors analyse whether the OECD's base erosion and profit shifting (BEPS) project would increase the use of the profit split method. After reviewing the current landscape in this context, the authors focus on situations in which the profit split method applies, the various approaches that can be used to split the profit among associated enterprises and reasons why the profit split method has been infrequently applied. Finally, the authors present their views on the application of the profit split method in light of the BEPS Action Plan.
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Author: 
Author: S.K. Bilaney
Author: Gabriella Cappelleri
Author: S. Zucchetti
Author: S.K. Bilaney
Author: C. Bagran Ilhan
Author: Robert T. Cole
Author: J.M. Kadet
Author: Alfred Dolge
Author: Vikram Chand