The Resource Does the profit split method apply to principal structures?

Does the profit split method apply to principal structures?

Label
Does the profit split method apply to principal structures?
Title
Does the profit split method apply to principal structures?
Creator
Subject
Language
eng
Summary
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?
Citation source
In: International transfer pricing journal. - Amsterdam. - Vol. 27 (2020), no. 4 ; p. 255-265
http://library.link/vocab/creatorName
Goppelsroeder, P
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • profit split method
  • transactional profit methods
  • Unified Approach (OECD)
  • arm's length principle
  • Pillar 1 (OECD)
Label
Does the profit split method apply to principal structures?
Instantiates
Publication
Label
Does the profit split method apply to principal structures?
Publication

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