The Resource Base erosion and profit shifting and business restructurings

Base erosion and profit shifting and business restructurings

Label
Base erosion and profit shifting and business restructurings
Title
Base erosion and profit shifting and business restructurings
Creator
Subject
Language
eng
Summary
In anticipation of the release of the new Chapter IX of the OECD Transfer Pricing Guidelines, this article looks at the potential impact that the outcome of the base erosion and profit shifting (BEPS) project will have on business restructurings. Specifically, the article examines some of the areas of convergence and divergence between the 2010 version of Chapter IX and the new guidance issued under the BEPS Actions 8-10 Final Reports (Aligning Transfer Pricing Outcomes with Value Creation). Whilst the new guidance arising from Actions 8-10 is anticipated to offer additional clarifications in the area of business restructurings, the authors note that there are additional areas of complexity which are likely to lead to increased controversy for multinational enterprises (MNEs), with double taxation as an inevitable result
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 44 (2016), no. 10 ; p. 769-773
http://library.link/vocab/creatorName
  • Hall, M
  • Wood, S
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • OECD Transfer Pricing Guidelines
  • reorganization
  • BEPS
Label
Base erosion and profit shifting and business restructurings
Instantiates
Publication
Label
Base erosion and profit shifting and business restructurings
Publication

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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