Draft OECD transfer pricing guidelines on related party financial transactions, slated for release this summer, will include important guidance for multinationals on intercompany loans, cash pooling, and reinsurance, though reaching consensus among countries on some fundamental issues is . . .
Officials representing 68 countries and jurisdictions on June 7 signed a multilateral instrument to amend their existing tax treaties, adding provisions designed to curtail multinational tax avoidance and strengthen tax dispute resolution . . .
The OECD today released a discussion draft providing guidance to tax administrations on how to implement transfer pricing guidelines on transfers of hard-to-value intangibles. An approach to hard-to-value . . .
Mansi Seth and Afaan Arshad of Nishith Desai Associates discuss today’s announcement that the Indian Union Cabinet has approved India’s signing of the multilateral instrument (MLI) to implement the tax treaty measures in the OECD/G20 base erosion profit shifting (BEPS) action plan . . .
US international transfer pricing attorneys Robert Feinschreiber and Margaret Kent discuss guidance developed during the OECD/G20 base erosion profit shifting (BEPS) project which applies transfer pricing concepts to contracts. . .
The OECD on March 24 made public 33 letters commenting on draft examples issued last January that address the application of the principal purpose test in tax treaties to non-collective investment . . .
Multinationals, particularly the largest firms, take advantage of profit shifting to low tax rate countries, mismatches between country tax systems, and preferential tax regimes to significantly lower their tax bills, though countries that strengthen their antiavoidance laws may be able . . .
In an effort to provide their tax administrations with tools to combat corporate tax avoidance through transfer pricing, officials from 7 more countries have signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large . . .
The British Virgin Islands will join the OECD/G20 Inclusive Framework, pledging to adopt and work toward the implementation of the minimum international tax standards in the OECD/G20 Base Erosion Profit Shifting . . .