![]() ![]() ![]() ![]() Given the above, taking into account the light of increased attention of tax authorities to the issue of TP, we recommend paying attention to the consistency of the compiled transfer pricing reports in your Group according to the new guidelines on TP from the OECD, as well as taking into account the planned changes to local legislation. It is expected that tax authorities will follow the recommendations and innovations of the latest edition, and among others by introducing new provisions on pricing financial transactions, the application of approach to valuation of intangible assets and the transactional profit split method into local legislation. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdiction and that the tax base reported by MNEs in their country reflects the economic activity undertaken therein and taxpayers need clear guidance on the proper application of the arm’s length principle. In today’s economy where multinational enterprises play an increasingly prominent role, transfer pricing continues to be high on the agenda of tax administrations and taxpayers alike. The report released today is significant because it is the first time the OECD Transfer Pricing Guidelines include guidance on the transfer pricing aspects of financial transactions, which will contribute to consistency in the interpretation of the arm’s length principle and help avoid transfer pricing disputes and double taxation. new section regarding financial transactions.approach to complicated assessment of intangible assets.comments on the application of the transactional profit split method.The document was updated with the following issues: The OECD Transfer Pricing Guidelines provide guidance on the application of the "arm’s length principle", which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises. supportive of transfer pricing advisory, design and planning, whereas the OECD BEPS Project approaches regulations as a response to aggressive tax planning. On 20 January 2022, the Organization for Economic Cooperation and Development ("OECD") has released a new edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which replaces the previous 2017 edition. ![]()
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |