Substance, not legal form, should drive an arm’s length transfer pricing policy. Paul Daly and Duncan Nott (BDO) provide a practical guide.
The OECD/G20 BEPS programme has been one of the biggest transformational events in international tax in decades. Against a backdrop of increasing politicised scrutiny into the tax affairs of multinationals BEPS was a high profile assignment for the OECD. It took the form of a two year project to ‘reset’ the fundamentals of an international tax system that had been outpaced by business change with an estimate of $100bn to $240bn of corporate tax being ‘lost’ each year.
To the OECD’s credit it delivered on the brief more or less on time in October 2015 presenting 13 final reports across the three key themes of transparency coherence and ‘substance’. That was just the beginning though. The world ‘post BEPS’ is...
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Substance, not legal form, should drive an arm’s length transfer pricing policy. Paul Daly and Duncan Nott (BDO) provide a practical guide.
The OECD/G20 BEPS programme has been one of the biggest transformational events in international tax in decades. Against a backdrop of increasing politicised scrutiny into the tax affairs of multinationals BEPS was a high profile assignment for the OECD. It took the form of a two year project to ‘reset’ the fundamentals of an international tax system that had been outpaced by business change with an estimate of $100bn to $240bn of corporate tax being ‘lost’ each year.
To the OECD’s credit it delivered on the brief more or less on time in October 2015 presenting 13 final reports across the three key themes of transparency coherence and ‘substance’. That was just the beginning though. The world ‘post BEPS’ is...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
