· Conforming changes to transfer pricing guidelines: The OECD is consulting until 16 August 2016 on amendments to Chapter IX (transfer pricing aspects of business restructurings) of the transfer pricing guidelines, to keep the existing guidance consistent with changes made by the 2015 BEPS reports on Actions 8–10 (transfer pricing) and Action 13 (transfer pricing documentation and country-by-country reporting). See http://bit.ly/29t5IHz. The changes aim to conform the existing general guidance in Chapter IX on risk and recognition of controlled transactions to the guidance contained in the revised Chapter I resulting from the 2015 BEPS Reports; and refine the existing guidance in Chapter IX with the updates to the rest of the guidelines resulting from the 2015 BEPS Reports.
· Attribution of profits to permanent establishments: The OECD is consulting until 5 September 2016 on this draft, which does not yet represent a consensus position. Views are sought on two scenarios that would particularly benefit from additional guidance. These are: dependent agent permanent establishments, including those created through commissionaire and similar arrangements; and warehouses as fixed place of business permanent establishments. A number of questions are identified for each type.
· Revised guidance on profit splits: The OECD is consulting until 5 September 2016 on this draft, which also does not yet represent a consensus. It aims to clarify and strengthen the guidance on the transactional profits-split method in the context of global value chains. In particular, it elaborates on two different approaches to splitting profits: transactional profit splits of actual profits; and transactional profit splits of anticipated profits. It also proposes further draft guidance on the appropriate application of transactional profit-split methods.
· Conforming changes to transfer pricing guidelines: The OECD is consulting until 16 August 2016 on amendments to Chapter IX (transfer pricing aspects of business restructurings) of the transfer pricing guidelines, to keep the existing guidance consistent with changes made by the 2015 BEPS reports on Actions 8–10 (transfer pricing) and Action 13 (transfer pricing documentation and country-by-country reporting). See http://bit.ly/29t5IHz. The changes aim to conform the existing general guidance in Chapter IX on risk and recognition of controlled transactions to the guidance contained in the revised Chapter I resulting from the 2015 BEPS Reports; and refine the existing guidance in Chapter IX with the updates to the rest of the guidelines resulting from the 2015 BEPS Reports.
· Attribution of profits to permanent establishments: The OECD is consulting until 5 September 2016 on this draft, which does not yet represent a consensus position. Views are sought on two scenarios that would particularly benefit from additional guidance. These are: dependent agent permanent establishments, including those created through commissionaire and similar arrangements; and warehouses as fixed place of business permanent establishments. A number of questions are identified for each type.
· Revised guidance on profit splits: The OECD is consulting until 5 September 2016 on this draft, which also does not yet represent a consensus. It aims to clarify and strengthen the guidance on the transactional profits-split method in the context of global value chains. In particular, it elaborates on two different approaches to splitting profits: transactional profit splits of actual profits; and transactional profit splits of anticipated profits. It also proposes further draft guidance on the appropriate application of transactional profit-split methods.
