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  • Price and value
    Price and value
    The issue of transfer pricing has become in recent years the pride and joy of the tax authorities and a challenge for MNE. Intensified activities of the OECD - the program BEPS and updated TPG, in conjunction with the legislative activity of the tax authorities creates the need for in-depth analysis of the seemingly well-known concepts and mechanisms, particularly in the area of valuation.
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  • G20 / OECD and BEPS
    G20 / OECD and BEPS
    The newest OECD carried out "on behalf of" the G20 developing a shocking speed. The beginnings seemed difficult but the project is alive and well.There is a growing challenge in front of a simple tax optimization. Well, the action generates reaction, life knows no vacuum so clever tax advisers' fees will increase.
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  • Intangible assets
    Intangible assets
    As part of the work on updating the OECD Guidelines, contained in the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in terms of Chapter VI (intangible assets) have been revised a number of issues with the exception of those covered by the project BEPS.
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Profit attribution to PE and revised Profit Splits

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Sunday, 16 July 2017 17:59

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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Sunday, 16 July 2017 17:40

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.

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New

  • Comparative analysis of intangible assets
  • Streamlining the implementation of BEPS
  • Application of the comparative method in TP
  • Valuation Methods in Transfer Pricing
  • Controversial method profit splits
  • DCF for everything in TPG
  • Price and value
  • G20/OECD and BEPS
  • Intellectual property
  • Whether the mark contributed in kind to a company subject to transfer pricing documentation?
  • Is the method of valuation used for the purpose of transfer pricing are different from those used for other purposes?

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