Profit Split: is it a realistic method without an APA?
Revised OECD guidance on Profit Splits I just read through the public discussion draft on the revised guidance on transactional profit splits (Please click for the official document as published by the OECD on July 4, 2016). The feeling I had after analysing these 20 pages was that I would (still) not feel very comfortable […]
Summary – OECD releases guidance on the implementation of country-by-country reporting
Following the endorsement of the BEPS Package by G20 Leaders in November, the focus has now shifted to ensuring a consistent implementation, including the new transfer pricing reporting standards developed under Action 13 of the BEPS Action Plan. Yesterday the OECD released further guidance on the implementation of CbC reporting on the following issues: […]
10 (strategic) questions to prepare for CbC reporting
As you are probably aware, MNE groups with a consolidated group revenue exceeding EURO 750 million (or local equivalent) need to comply with the Country-by-Country (‘CbC’) reporting requirements. MNEs need to prepare CbC reporting before the end of 2017, or at a later date, dependent on the country. Although CbC reporting gives rise to […]