Profit attribution to PE and revised Profit Splits
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The OECD has issued new calls for discussion in the areas of: Attribution of Profits to Permanent Establishments and updated guidance on the profit allocation methodology Revised Guidance on Profit Splits.
Written comments should be sent by September 15, 2017. Public consultations are planned for November this year, at the OECD Conference Center in Paris.
The HTVI (Hard to Value Intangibles) and the responsible use of the Profit Splits method in the transfer pricing process are now creating tough challenges for tax experts, taxpayers, and tax authorities.
Cooperation platform
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Joint International Initiative: International Monetary Fund (IMF), Organization for Economic Co-operation and Development (OECD), United Nations (UN) and World Bank Group under the name Platform for Collaboration on Tax (TPT).
The purpose of the published guide is to identify developing countries the solution to the lack of data needed to apply Arm's Length in the transfer pricing process in this comparative analysis.