Transfer pricing in a post-BEPS world

The Resource Transfer pricing in a post-BEPS world

Label

Transfer pricing in a post-BEPS world

Language

eng

Summary

The OECD's Base Erosion and Profit Shifting (BEPS) project promises to make effective inroads into the much criticized corporate tax strategy known as aggressive transfer pricing, whereby the profitability of subsidiaries in different jurisdictions is "managed" via mispricing with the intent of minimizing the corporation's overall tax burden. This book analyses the trends, and proposes reforms which would ensure that transfer pricing outcomes are better aligned with economic activitie and value creation, which achieves a more equitable distribution of profits among different countries. It provides an in-depth analysis of several topics, the related BEPS proposals and suggestions for future solutions. It looks, among others, at the following topics: arm's length principle and its ongoing development; allocation of risk and recharacterization; intangibles (both license model and cost contribution arrangements); interest deductions and intra-group financing; low value-adding services; commissionaire arrangements and low-risk distributors; attribution of profits to permanent establishments and documentation requirements (including country-by-country reporting)

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction

Series statement

EUCOTAX series on European Taxation

Series volume

vol. 50

Context

Context of Transfer pricing in a post-BEPS world

Work of

Transfer pricing in a post-BEPS world

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