Revised Guidance on the Application of the Transactional Profit Split Method : Evolution Or Revolution?. PDF Download

Author: S. Zucchetti
Publisher:
ISBN:
Category :
Languages : en
Pages :

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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: Gabriella Cappelleri
Publisher: Kluwer Law International B.V.
ISBN: 9403524316
Category : Law
Languages : en
Pages : 341

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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: M. Kobetsky
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description
In 2018, the Organisation for Economic Co-operation and Development/Group of Twenty (OECD/G20) Inclusive Framework on base erosion and profit shifting (BEPS): action 10 issued revised guidance on the transactional profit-split method. Regrettably, the revised guidance failed to provide the opportunity for the profit-split method to be more often the most appropriate transfer-pricing method. The revised guidance expressly states that the lack of comparable uncontrolled transactions, by itself, is not a basis for the use of the profit-split method. Under the former guidance, the profit-split method was used infrequently. In the revised guidance, the threshold requirements for the use of the profit-split method are still restrictive. Consequently, it is likely that the profit-split method will rarely be the most appropriate transfer-pricing method. Nevertheless, the residual profit-split method is being considered for BEPS action 1, on the taxation of the digital economy. Two of the proposals under pillar 1 of the Inclusive Framework's 2019 short policy note involve the use of the residual profit-split method to allocate profits. These proposals involve new profit allocation rules that go beyond the arm's-length principle.

Author: S.K. Bilaney
Publisher:
ISBN:
Category :
Languages : en
Pages :

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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: P. Goppelsroeder
Publisher:
ISBN:
Category :
Languages : en
Pages :

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Book Description
The purpose of this article is to address whether the profit split method (PSM), in particular, the transactional PSM (TPSM) applies to principal structures in multinational enterprises (MNEs). It takes into account the shift in focus of the post-BEPS amendments, especially the 2017 OECD Guidelines and the 2018 Revised Guidance on the Application of the Transactional Profit Split Method. The main focus is on the possible departure from the arm's length principle in the 2019 consultation document of the OECD on a unified approach to profit allocation under Pillar One. Will this unified approach (deemed 'PSM' on consolidated MNE level) improve the world order between global MNEs and local tax authorities and lead to less disputes and less double taxation?

Author: Björn Heidecke
Publisher: Springer
ISBN: 9783319733319
Category : Business & Economics
Languages : en
Pages : 725

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Book Description
Intangible assets are becoming increasingly important as value drivers for multinational companies. It is a strategic question how to allocate intangibles within the multinational corporation. It needs to be defined by whom and under which conditions they can be utilized. Typical IP migration models such as licensing, joint development and transferring are becoming a focal point within tax audits across the globe. Hence,defining an intangibles system that fulfils the tax requirements is of utmost strategic importance for multinational corporations. A central question is how to value intangibles in line with the arm’s length principle as is required internationally for transfer pricing purposes. Edited by leading transfer pricing and valuation experts in Europe, this comprehensive book offers practitioners an effective road map for identifying, valuing and implementing intangibles for transfer pricing purposes under consideration of both the OECD and local perspectives. It is therefore a must-have book for transfer pricing and valuation practitioners on all levels of experience. The book starts with an introduction to the role of intangibles in the world of transfer pricing including typical intangibles migration models. It describes common intangible assets across all types of industries, including e.g. automotive, consumer goods and software.Using several numerical examples, the book then covers state-of-the-art valuation methods including how to apply these methods in practice in a way consistent with the OECD Transfer Pricing Guidelines. The different country chapters written by local experts provide country-specific guidance on the legal framework concerning intangible assets from a transfer pricing and valuation perspective. Finally, the book covers practical advice on the implementation of an intangible assets system. This book offers invaluable guidance to practitioners seeking tools to apply the arm’s length principle in the world of intangibles.

Author: Steve Edge
Publisher:
ISBN: 9781804491782
Category :
Languages : en
Pages : 0

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Book Description

Author: Gar Alperovitz
Publisher: Chelsea Green Publishing
ISBN: 1603584919
Category : Business & Economics
Languages : en
Pages : 226

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Book Description
"Never before have so many Americans been more frustrated with our economic system, more fearful that it is failing, or more open to fresh ideas about a new one. The seeds of a new economy--and, if we act upon it, a new system--are forming. What is that next system? It's not corporate capitalism, not state socialism, but something else--something entirely American. In What Then Must We Do?, Gar Alperovitz speaks directly to the reader about why the time is right for a revolutionary new economy movement, what it means to democratize the ownership of wealth, what it will take to build a new system to replace the decaying one--and how to strengthen our communities through cooperatives, worker-owned companies, neighborhood corporations, small and medium-size independent businesses, and publicly owned enterprises. For the growing group of Americans pacing at the edge of confidence in the old system, or already among its detractors, What Then Must We Do? offers an evolutionary, common-sense solution for moving from despair and anger to strategy and action."--Publisher's website.

Author: El Bachir Boukherouaa
Publisher: International Monetary Fund
ISBN: 1589063953
Category : Business & Economics
Languages : en
Pages : 35

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Book Description
This paper discusses the impact of the rapid adoption of artificial intelligence (AI) and machine learning (ML) in the financial sector. It highlights the benefits these technologies bring in terms of financial deepening and efficiency, while raising concerns about its potential in widening the digital divide between advanced and developing economies. The paper advances the discussion on the impact of this technology by distilling and categorizing the unique risks that it could pose to the integrity and stability of the financial system, policy challenges, and potential regulatory approaches. The evolving nature of this technology and its application in finance means that the full extent of its strengths and weaknesses is yet to be fully understood. Given the risk of unexpected pitfalls, countries will need to strengthen prudential oversight.

Author: National Intelligence Council
Publisher: Cosimo Reports
ISBN: 9781646794973
Category :
Languages : en
Pages : 158

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Book Description
"The ongoing COVID-19 pandemic marks the most significant, singular global disruption since World War II, with health, economic, political, and security implications that will ripple for years to come." -Global Trends 2040 (2021) Global Trends 2040-A More Contested World (2021), released by the US National Intelligence Council, is the latest report in its series of reports starting in 1997 about megatrends and the world's future. This report, strongly influenced by the COVID-19 pandemic, paints a bleak picture of the future and describes a contested, fragmented and turbulent world. It specifically discusses the four main trends that will shape tomorrow's world: - Demographics-by 2040, 1.4 billion people will be added mostly in Africa and South Asia. - Economics-increased government debt and concentrated economic power will escalate problems for the poor and middleclass. - Climate-a hotter world will increase water, food, and health insecurity. - Technology-the emergence of new technologies could both solve and cause problems for human life. Students of trends, policymakers, entrepreneurs, academics, journalists and anyone eager for a glimpse into the next decades, will find this report, with colored graphs, essential reading.