ICC Response to OECD BEPS Discussion Draft on the Revised Guidance on Profit Splits
In the context of the OECD Base Erosion and Profit Shifting (BEPS) Project mandated by the G20, ICC submitted high level and fundamental comments on the OECD’s Discussion Draft on the Revised Guidance on Profit Splits.
ICC submitted high level and fundamental comments to OECD’s Discussion Draft on the Revised Guidance on Profit Splits.
The Discussion Draft deals with the clarification and strengthening of the guidance on the transactional profit split method, as set out in the BEPS Actions 8-10 of the 2015 Final Report.
The Discussion Draft concentrates on the guidance proposed to be included in Chapter II, and is provided within a framework of other relevant guidance. In particular the revisions to Chapter I set out guidance on how accurately to delineate the actual transaction between the associated enterprises, including an understanding of the broader context of the value chain to which they contribute, and of a requirement to select the most appropriate transfer pricing method to the circumstances of the case which underpins the discussion of transfer pricing methods in Chapter II. In addition, the revisions to Chapter VI include relevant guidance on identifying and evaluating intangibles.
It is to this end that ICC has submitted comments for the OECD’s consideration.
- ICC Carbon Pricing Principles
- ICC Comments on the 2021 EU Consultation on Fair Taxation of the Digital Economy
- ICC Comments on UN Tax Committee Discussion Draft: Revised Proposal for a change to the definition of royalties in Article 12 of the United Nations Model Double Taxation Convention Between Developed and Developing Countries
- ICC Comments on OECD public consultation document on the review of BEPS Action 14: Making Dispute Resolution Mechanisms More Effective
- ICC Comments on OECD public consultation document: Reports on the Pillar One and Pillar Two Blueprints: Tax challenges arising from digitalisation
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