“Introducing the Profit Split Method (PSM) – To Apply or Not to Apply, This is a BEPS Question,” explores the PSM’s origins and its role in profit distribution among controlled entities. It demonstrates PSM’s versatility in scenarios involving nonroutine intangible property, significant entrepreneurial risk, and integrated value chains. The PSM process aligns transfer pricing outcomes with economic activities and value contributions, thus supporting the BEPS objective. By employing the PSM, MNEs can robustly substantiate their transfer pricing policies and results. Continue reading
Category Archives: OECD
“Global Trends in Transfer Pricing”
I examine the intricate and evolving transfer pricing landscape in this insightful article. From the globally converging corporate income tax rates aimed at diminishing tax base erosion to the intense focus on intangibles in related legislation, the article provides a comprehensive overview of the key 2019 transfer pricing trends. The article also highlights the rising compliance and risk management burdens for multinational enterprises (MNEs) and the innovative use of technology to improve global transfer pricing processes. Finally, focusing on the U.S. Tax Cuts and Jobs Act (TCJA) of 2017 and its implications, the piece offers a detailed look at the changing dynamics of global tax competition. Learn more about how these shifts impact MNEs and their approach to managing transfer pricing risks. Continue reading
Pros and Cons of Safe Harbors, and Advice to Tax Authorities
Why is it worth weighing pros and cons of safe harbors*? Because the OECD’s June 6, 2012 draft endorses safe harbors and presents three sample memoranda that countries may use to negotiate bilateral safe harbors. Also, most would say that the IRS has been successful with instituting safe harbors on interest rates for intercompany loans, and … Continue reading
Did it take almost 2.5 years for the CRA to read the 2010 version of the OECD TP Guidelines?
Did it take almost 2.5 years for the CRA to read the 2010 version of the OECD TP Guidelines? Apparently. CRA released Transfer Pricing Memorandum 14 on October 31, 2012, basically saying they agree with the OECD. Continue reading